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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />DATE: <br />TO: <br />March 28, 2011 <br />Marcia Talvitie <br />COLORADO <br />D I V I S I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Mike King <br />FROM: Joe Dudash,.-? Executive Director <br />Loretta E. Pineda <br />RE: New Horizon 2"Mine, Permit No. C-81-008, Western Fuels Colorado Director <br />Partial Phase 2 and 3 Bond Release, SL-12, Soil Loss Comparison <br />Adequacy Review <br />As you had requested, I have reviewed the soil loss comparison calculations provided in the Partial Phase <br />2 and 3 Bond Release submittal dated March 15, 2011 for the New Horizon 2 Mine, SL-2. The basic <br />methodology that was employed by Greg Lewicki in SL-12 was the same as was done in SL-11 in 2008. <br />Concerning the determination of the soil erodibility factor "K" on page 17, a statement is made <br />that the soil on the reclaimed area is similar to the soil that was salvaged from that area before <br />mining. However, comparison of the soil types listed in Table 1 on page 18 with the baseline soil <br />types shown on soil Map 2.04.9-1 appear to show a couple of discrepancies. First, Barx soil and <br />Ustic Torriorthents are listed in Table 1 but do not appear in the phase 2 release area shown on <br />Map 2.04.9-1. Second, soil types Bowbac-Bowdish Complex, Haplargids-Endoaquolls <br />Association, Bowdish-Bowbac Complex and Wahweap, map units 98D, 98F, 98G and 98H <br />respectively, are shown on Map 2.04.9-1 in the phase 2 release area but do not appear in Table 1. <br />Please explain. <br />2. For the cover factor "C" determination for the pre-mine condition for irrigated pasture, there <br />appears to be a minor math miscalculation at the top of page 22. The final "C" factor of .0258 <br />was obtained by adding .0008 to .025. It appears, however, that .0008 should be subtracted from <br />.030, resulting in a value of .0292. If you agree, please revise pages 22, 23 and 29 accordingly. If <br />you do not agree, please explain. <br />3. For the cover factor "C" determination for the post-mine condition for irrigated pasture, there <br />appears to be a minor math miscalculation in the middle of page 23. The change, however, would <br />not affect the result but it may avoid some confusion later. The final "C" factor of .0299 was <br />obtained by subtracting .000936 from.03. It appears, however, that .000936 should be subtracted <br />from .031, resulting in a value of .030064. If you agree, please revise page 23 accordingly. If you <br />do not agree, please explain. <br />4. On page 23, there is a sentence that states that the actual canopy is 45.7%. As stated earlier in the <br />same paragraph, however, it appears that this value should be 23.4%. Please revise accordingly. <br />5. The Division understands that Western Fuels will reconsider its methodology in calculating the <br />soil loss comparison as it relates to the alfalfa cover. <br />c:\word2007\newhorizon2\sl l 2memo 1 <br />Office of Office of <br />Mined Land Reclamation Denver • Grand )unction • Durango Active and Inactive Mines