2010-05-14_REVISION - C1982056 ‎(2)‎

• Permit No: C1982056
• IBM Index Class Name: REVISION
• Doc Date: 5/14/2010
• Doc Name: Adequacy Response Review
• From: Janet Binns
• To: Jason Musick
• Type & Sequence: RN5
• Email Name: JHB
• Email Name: JDM
• Media Type: D
• Archive: No

C1982056, RN5, Adequacy Review 2 5/14/2010
discussion regarding sealing the boreholes. Please direct the Division to where sealing of the NMD
power boreholes is discussed in the PAP, or include a discussion of sealing these NMD boreholes.
(Rule 4.07.3).
TCC's response on revised page 2.05-106.2 is acceptable.
9. Rangeland seed mix, Table 55 and text on page 2.05-112 discuss seeding techniques to be utilized
for the reclaimed areas. The discussion in the text references studies from the 1970's and older.
While the results of these studies are valid, observation of thirty years or more of reclaimed coal
mines in Northwest Colorado have resulted in planting techniques that help with establishment of
diverse permanent plant communities on reclaimed lands. The Division conducted a shrub
establishment study in conjunction with Colorado State University, Department of Range Science,
and three coal mine operators in Northwest Colorado. The study recognized the difficulties a number
of operators were having establishing shrub species using traditional reclamation methods. The
study initiated in 2000, eight years of observations have provided the Division, CSU and coal mine
operators valuable results regarding seeding techniques that have favorable shrub establishment.
The current rangeland seed mix (Table 55) and seeding method (P. 2.05-112) in the Foidel Creek
permit is expected to encounter similar difficulties experienced at other locations in Northwest
Colorado based upon the similarities in seed mix, environment, and seeding techniques. The Division
suggests re-evaluation of the seed mix and planting methods for the rangeland areas incorporating
some of the more recent study findings to assist in successful re-establishment of a diverse rangeland
community that will achieve Foidel Creek Mine's reclamation success standards.
TCC provided Revision to the Rangeland Seed mix, Table 55. Some of the more aggressive grass
species were removed from the seed mix. An increase in forb seeding rates was noted as well. TCC
also revised Section 2.05.4 of the PAP to utilize seeding methods that have shown better shrub and
forb establishment such as strip seeding or live transplanting of shrub species in concentrated areas.
This response addresses the Division's concerns.
20. RCE= $7,832,530.89. TCC's response to Adequacy questions Nos. 1 and 2 will require revision to
task no. 069, which will result in a change to the Reclamation Cost Estimate total. Please find copies
of the Division's estimate attached to this letter.
TLC's response indicates that the cost for the cover material on the "old" RDA is already included in
TLC's estimate.
The Division updated the bond costs in May 2010 since 16 months had passed since the Division's
RN5 estimate in January 2009. The Division included estimated costs for revisions that had been
approved since the January 2009 estimate. The updated RN5 Reclamation Cost Estimate for the
Foidel Creek Mine is $9,760,543.96.
The overall increase in the estimate can be attributed to the City Cost Index. This value is obtained
from RS Means: 2010 Site Work and Landscape and Cost Data. This value is applied to demolition
costs and is developed from actual contract costs in the region the work is performed from data