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,;, ° <br />J. E. STOVER & ASSOCIATE4 INC. <br />2352 NORTH 7th STREET, UNIT B <br />GRAND JUNCTION, COLORADO 81501 <br />PHONE: (970) 245-4101, FAX 242-7908 <br />MINE ENGINEERING <br />MINE RECLAMATION <br />November 17, 2010 <br />?v 3 <br />lb1C? ?? <br />Marcia Talvitie <br />Division of Reclamation Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Request for Phase II Bond Release <br />Soils Information <br />Permit C-1991-078 <br />Dear Ms. Talvitie: <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />The DRMS' inspection report dated June 3, 2010 detailed the results of a bond release <br />inspection held on the same date. The report states that topsoil depths in mining area <br />number 1 were measured at twelve locations during the inspection with an average depth <br />of 9.1 inches. The permit currently requires a 10 replacement depth. The inspection <br />report states the Division's preliminary determination is that an adequate soil thickness was <br />not replaced within Mining Area No. 1. Honeywood Coal Company (HCC) disagrees with <br />that statement. Field depth measurements provide a snapshot of topsoil replacement <br />depth. A determination of actual average replacement depth would require developing and <br />implementing a systematic and representative soil sampling plan. Additionally, baseline <br />soil depth surveys are not designed to provide data necessary to determine exact topsoil <br />salvage volumes. Soil depth surveys provide an operator guidance regarding the depth of <br />soil that is suitable for salvage in different soils. <br />Depths of topsoil replacement were measured in Mining Area No. 3 at six locations during <br />the inspection with an average depth of 12.5 inches. The permit currently requires a 16" <br />replacement depth, but that value was determined by averaging the resource available <br />from a larger area. The Operator was requested to provide an assessment of the average <br />soil thickness that would have been available for salvage based on pre-mining assessment <br />and the acreage of specific soil types actually disturbed within Mining Area No. 3. The <br />problem with this request is that the Soil Classification Map No. 112, is hand drafted on a <br />quad base at a 500 foot scale. The lines on the map are 20 feet wide. It would not be <br />unexpected that the soil type lines could be off by 100 feet or more. However an estimate <br />was prepared of the acreage disturbed in three soil types. The information is summarized <br />in the following table.