2010-05-10_GENERAL DOCUMENTS - C1981019

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need for several points of compliance). Additional information can be found in the Division's 2005 Midterm Review, the Preliminary Adequacy Review Letter for Permit Revision 02 and the Preliminary Adequacy Review Letter for Permit Renewal 05. Rule 4.06 - Topsoil 16. On Page 4.06-1 Colowyo indicates that the mine's topsoil balance is shown on Table 2.05-1, which is current as of October 2005. This table is out of date and needs to be updated with the current topsoil balance information. The Division suggests that an alternative to this table, which will be out of date again after it is submitted (due to ongoing topsoil salvage and replacement activities), would be to eliminate this table in the permit and provide the information in the Annual Reclamation Report (ARR). Colowyo currently provides a yearly topsoil balance in the ARR, which provides the most up to date topsoil balance information available. Please reference this table in the ARR on Page 4.06-1 as well as Table 2.05-1 (or in lieu of Table 2.05-1 if it is removed). Please update Table 2.05-1 if it is not replaced. 17. On Page 4.06-3 Colowyo commits to ripping or scarifying regraded surfaces prior to topsoil replacement to alleviate compaction to help prevent slippage and to help with root penetration. In 2007 Colowyo backfilled and regarded approximately 42 acres in the West Pit that was not contiguous with any of their other reclamation. It was agreed that this area would not be topsoiled or seeded at that time. This area is now contiguous with backfilling and grading that was completed in 2009 and 2010 (and will be topsoiled and seeded in 2010) and will need to be topsoiled and reseeded in 2010. In addition, since this area has gone through several freeze-thaw cycles, Colowyo will need to heavily rip this area to alleviate compaction and ensure proper topsoil stability and root penetration. Rule 4.09 - Disposal of Excess Spoil 18. On the first page of Rule 4.09 - Disposal of Excess Spoil, the title to the section reads: 4.09 - Disposal of Excess "Spill". Please change "Spill" to "Spoil". Rule 4.13 - Contemporaneous Reclamation 19. The text in the permit application regarding the approved variance from contemporaneous reclamation for the multiple seam mining operation at the Colowyo Mine is vague and not very descriptive. Please add detail to this section including more definitive timing and a more complete description of the mining and reclamation sequence, which describes why the variance from contemporaneous reclamation is needed. Please include information regarding how Colowyo tracks its backfilling and grading to ensure it is in compliance with Rule 4.13. Colowyo Mine Permit No. C-1981-019 2010 Midterm Review 10 May 2010 13