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INTEROFFICE MEMORANDUM <br />TO: KEENESBURG FILE C1981-028 <br />FROM: JANET BINNS <br />SUBJECT: KEENESBURG 2009 ANNUAL RECLAMATION REPORTS <br />DATE: 4/1/2010 <br />Coors Energy Company submitted the 2009 ARR on February 25, 2010. The Keenesburg Mine permit, C-1981- <br />028, page 117, has committed to submitting the Annual Reclamation Report by the end of February each year. The <br />submitted report is in compliance with the approved permit. <br />Precipitation record for 2009 totaled 16.5 inches. <br />No new areas were disturbed by CEC operations in 2009. CEC continued to place ash, spoil cover in the south end <br />of B pit. Reclamation parcel 31 was seeded with sorghum cover crop in the spring of 2009, and the permanent seed <br />mix on October 16, 2010. Comparison with the seed tags of the permanent seed mix and the approved seed mix in <br />the permit found some minor discrepancies. <br />All approved plant species are included in the seeded permanent seed mix as reported on the seed tags. However <br />three species were seeded at rates different than those shown in the approved seed mix on page 115 of the PAP. <br />Indian Ricegrass was seeded at a rate of 1.0 lbs PLS/acre instead of the approved rate of 0.2 Is PLS. Yellow <br />Indiangrass was seeded at a rate of 1.5 lbs PLS/acre instead of the approved rate of 1.0 lbs PLS/acre. And <br />Thickspike wheatgrass was seeded at a rate of 0.33 PLS/acre instead of the approved rate of 1.51bs PLS/acre. <br />Please provide an explanation to the Division as to the variance of the seeding rate of the species in question. No <br />unapproved species were included in the mix. <br />CEC reports that in 2009, the Keenesburg mine had a total of 438+/- (acres rounded to nearest whole number) <br />disturbed acres. Of the 438 disturbed acres, 251+/- (rounded to nearest whole number) acres had been backfilled <br />and graded. No new areas had received topsoil (topsand) in 2009, keeping the total topsoiled acreage to 251 acres. <br />CEC seeded 12 acres with the permanent seed mix in 2009. This brings the total seeded area to 251 acres. These <br />acreage values agree with values reported in 2008 by CEC. DRMS proposed to approve a Phase III bond release of <br />165.29 acres in October 2009. The bond release decision was not final until January 2010, so CEC did not report <br />these acres in 2009 ARK <br />CEC submits results of ash disposal with the Annual Reclamation Report. The volume of ash placed in the disposal <br />area, and the results on chemical analysis sample of bottom ash and flyash are included with the report. In 2009, <br />CEC reports that 38,594 tons of mixed flyash and bottom ash were disposed of in the B Pit at the Keenesburg Strip <br />Mine. Two samples, one flyash sample and one bottom ash sample, were analyzed for TCLP metals (leached), and <br />TCLP mercury (leached). Results of the bottom ash sample recorded Barium at 3.6 mg/L. The lowest quantitation <br />limit reported by the laboratory is 2 for barium using this method, and the regulatory action limit for Barium is 100 <br />mg/L. The measured value for Barium for the bottom ash sample is very low and not identified as a concern. All <br />other parameters analyzed for the bottom ash and flyash samples were below the detection limits for the associated <br />analyses. <br />CEC revised the quantity of spoil available in 2009 via TR40, and subsequently revised the post-mining contours of <br />the Long term spoil pile. Review of the reported Spoil Mass balance (page 106, 2009 Annual Hydrology and <br />Reclamation Report) finds some discrepancies;