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Interoffice Memo <br />April 12, 2010 <br />To: Rob Zuber <br />From: Janet <br /> <br />RE: Review of` Renesb64Mine, C1P81-028, 2009 Annual Reclamation Report <br />On April 12, 2010, Mr. Don MacDonald telephoned to inquire about my comments regarding the review of <br />the Keenesburg 2009 Annual Reclamation Report. My comments compared the seed tags from the <br />permanent seed mix used to seed Reclamation Parcel No. 31 to the approved permanent seed mix. My <br />comments from my April 1, 2010 memo are included below: <br />No new areas were disturbed by CEC operations in 2009. CEC continued to place ash, spoil cover in the south end of B pit. <br />Reclamation parcel 31 was seeded with sorghum cover crop in the spring of 2009, and the permanent seed mix on October 16, <br />2010. Comparison with the seed tags of the permanent seed mix and the approved seed mix in the permit found some minor <br />discrepancies. <br />All approved plant species are included in the seeded permanent seed mix as reported on the seed tags. However three species were <br />seeded at rates different than those shown in the approved seed mix on page 115 of the PAP. Indian Rice <br />,grass was seeded at a <br />rate of 1.0 lbs PLS/acre instead of the approved rate of 0.2 lbs PLS. Yellow Indiangrass was seeded at a rate of 1.5 lbs <br />PLS/acre instead of the approved rate of 1.0 lbs PLS/acrr. And Thickspike wheat grass was seeded at a rate of 0.33 PLSI acre <br />instead of the approved rate of 1.5 lbs PLS/acre. Please provide an explanation to the Division as to the variance of the seeding <br />rate of the species in question. No unapproved species were included in the mix. <br />Coors Energy Company (CEC) re-evaluated the approved seed mix found on page 115 of the PAP, and <br />could find no discrepancy with the seed tags. My further investigation of this matter found an apparent <br />flaw in the Division's imaging system. When I had searched the imaging system for the current approved <br />seed mix, I searched the database to find permit section "2.05.4". The resulting document provided me <br />with an approved seed mix on permit page 115. However, this page was dated 5/96. If I had conducted a <br />more general search for permit section "2.05", the imaging system would have shown me several files with <br />various updated dates. I would have chosen the most recently updated file of permit page 115. The current <br />approved seed mix found on permit page 115 does not have an approval date at the bottom of the page. <br />This version is in agreement with that page found in the paper copy of the PAP. Nothing in the imaging <br />system provided me any information that page "115 dated 5/96" had been subsequently updated. <br />Review of the current approved seed mix to the seed tags provided by CEC found the seed mix used to <br />seed reclamation parcel No. 31 in October 2009, is in agreement with the approved permanent seed mix. <br />Nothing further is needed from CEC regarding the seed mix used in 2009.