2010-05-25_REVISION - C1991078

• Permit No: C1991078
• IBM Index Class Name: Revision
• Doc Date: 5/25/2010
• Doc Name: Review Memo on Topsoil & Revegetation
• From: Dan Mathews
• To: Marcia Talvitie
• Type & Sequence: SL2
• Email Name: SB1
• Email Name: DTM
• Email Name: MLT
• Media Type: D
• Archive: No

STATE OF
COLORADO
DIVISION of RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman 6t., Room 215
Denver, Colorado 80203
COLORADO
Phone: [phone]
D I V I St 0 N OF
RECLAMATION
FAX: [phone]
MINING
SAFETY
DR MS
DX1MS II TE p NAL MEMORANDUM
Ritter, Jr.
Governor
James B. Martin
Executive Director
Date: May 2, 2010
To: Marcia Tal itie
r {
From. Dan Mathews
Hamilton SL -02 Phase II B ond Release
Permit No. C- 1 991 -078
Pursuant to your request I have reviewed the topsoil replacement and revegetation related sections of
the above referenced bond release application. The application was submitted by ,lira Stover,
consulting engineer, on behalf of Honeywood Coal Company, under cover letter dated October 29,
2009. The contents of the application included an 18 item listing addressing the general requirements
for a bond release application, a certified statement, and a neap of the release request area. Attached to
the application was a rvegetatlon monitoring report titled gait -2009, dated October 2009,
prepared by Cedar Creek Associates, Inc CCA.. The report included vegetation monitoring data,
summary tables and charts, and narrative evaluation. A final component of the application was a
Supplemental Topsoil Information submittal, provided by Jinn Stover under cover letter dated
December 15, 2009. The submittal included baseline soil physical and chemical data and horizon
thicknesses. The report also included projected soil salvage volumes and thicknesses for the various
mining areas. I reviewed the SL -02 application and both supplemental reports. In addition, I reviewed
the various sections of the approved pen - nit application related to soil and vegetation requirements, and
the most recent renal findings document (RN-03 Findings, dated 3/13/2007).
I have a number of review comments,, listed below. There are significant flaws M the application
related to vegetation cover success demonstration, that would appear to disallow approval of the
requested Phase 11 bond release. These flags are addressed in Adequacy Item #1, below.
1.
Rule 3.03.1(2)(b) states that up to % of the applicable bond amount shall be released upon
the establishment of vegetation which "supports the approved postmining land use and which
-meets the approved success standard for cover, ...based on statistically valid data collected
during a single year of the liability period ". Narrative in Item #16 (description of results
Office of office of
Mined Land Reclamation Denver • Grand junction • Durango Active and Inactive Mines