2011-04-04_REVISION - C1981008

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 4/4/2011
• Doc Name: 2nd Adequacy Review
• From: Joe Dudash
• To: Marcia Talvitie
• Type & Sequence: SL12
• Email Name: MLT
• Email Name: JJD
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203 D
COO
I O VI E SL I ORN A D OF
F
D
Phone: [phone] RECLAMATION
FAX: [phone] M I N I N G

DATE: April 4, 2011 SAFETY
John W. Hickenlooper
TO: Marcia Talvitie Governor

FROM:
Joe Dudash Mike King
Executive Director
Loretta E. Pineda
RE: New Horizo ,2 "n e, Permit No. C-81-008, Western Fuels Colorado Director
Partial Phase 2 and 3 Bond Release, SL-12, Soil Loss Comparison
Second Adequacy Review
I have finished my review of Western Fuels-Colorado's responses dated March 30, 2011 to the Division's
memo dated March 28, 2011 concerning the soil loss comparison for SL-12. In summary, the Division's
questions concerning the soil loss comparison were answered satisfactorily, as detailed later in this memo.
The soil loss comparison provided in the submittal dated March 30, 2011 is acceptable to the Division.
It should be noted that, in this newly revised soil loss comparison, the calculated sediment loss for the
post-mining situation is actually larger than that for the pre-mining situation. However, because the
calculated soil loss values are so small, the Division agrees with Western Fuels' argument that there is
essentially no sediment loss with both the pre-mine and post-mine conditions.
1. Concerning the determination of the soil erodibility factor "K" on page 17, a statement is made
that the soil on the reclaimed area is similar to the soil that was salvaged from that area before
mining. However, comparison of the soil types listed in Table 1 on page 18 with the baseline soil
types shown on soil Map 2.04.9-1 appear to show a couple of discrepancies. Please explain.
The Division has no further concerns. Western Fuels revised page 18 and added a note to the
bottom of Table 1 on page 19 to explain that NRCS soil survey designations were used for the
soil loss comparison evaluation for SL-12 whereas the pre-mine baseline soil survey did not. An
examination of the applicable soil types shown on the NRCS website verified the SL-12 soil type
information.
2. For the cover factor "C" determination for the pre-mine condition for irrigated pasture, there
appears to be a minor math miscalculation at the top of page 22.
The Division has no further concerns. Since Western Fuels revised its methodology concerning
the alfalfa cover, this cover factor calculation was no longer needed.
3. For the cover factor "C" determination for the post-mine condition for irrigated pasture, there
appears to be a minor math miscalculation in the middle of page 23.
The Division has no further concerns. Since Western Fuels revised its methodology concerning
the alfalfa cover, this cover factor calculation was no longer needed.
1
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines