2011-05-05_REVISION - C1981008

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 5/5/2011
• Doc Name: Adequacy Review No. 4 Letter
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: SL12
• Email Name: MLT
• Email Name: SB1
• Media Type: D
• Archive: No

C-1981-008 - SL-12
Adequacy Review No. 4
5 May 2011
Page 5 of 10
accomplished for those areas. And yet, WFC did make significant, unexplained changes to that portion of
Map 2.05.4-4. These TR-57 thicknesses were then applied to the SL-12 bond release application.
The Division has discovered that Map 2.05.4-4 topsoil replacement thicknesses east of 2700 Road were
changed yet again with PR-06, despite the fact that PR-06 was intended to apply only to mining and
reclamation of lands west of 2700 Road.
Revisions Made to Map 2.05.4-4 - Topsoil Redistribution
MR51 / Required PR-06
Topsoil PR-05 TR54 TR-57 Thickness
Dec- Measured
Sample Point Apr-2000 Oct,01- Mar-2009 SL-12 App
2010 Thickness
Jul'07 Aug-2009
U TS54 Block A Block A 4.0' (48")
w3 TS58 '/ /
O " 3.0' (36")

2.26' l 00' 11 "-15" /

„
„ (2

15
-
39
23 '
"
TS62 Block B Block B 12"-24" Lifts) 3.1
(37
)
TS63 7
'
/ 0.83
/
3.6' (43")
0
'
1. 00'
1
TS49 3.3' (40")
TS48 +150N
' 2.9' (35")
TS50 9"/ 25" / 12-24" 37"-49" 21
(2 4.0' (48")
TS51* 1815-27" 18"-27" Lifts) 0.9'(11")*
TS69 4.0' (48")
* Located near BB Road; explanation provided in Aug. 2010 response
In the text and table above, the Division has limited its specific comments to reclaimed lands included within
the current Phase II bond release application. It seems highly probable that topsoil replacement thicknesses
for the remaining portions of the permit area located east of 2700 Road have been altered in similar fashion,
without explanation and without notice.
Please review the information provided herein, together with any changes made to topsoil replacement
requirements for the remainder of the permit area. Please provide a clear and thorough justification for
the numerous alterations that have been made to Map 2.05.4-4, including a discussion of the actual
replacement thicknesses measured.
Phase III Bond Release Request
WFC has requested Phase III release for 126.1 acres of irrigated pasture and 23.8 acres of dryland pasture that
were initially revegetated in 1998. The Division allows for Phase III bond release upon successful completion of
all reclamation plan requirements for the area in question, including demonstration of conformance with all
applicable revegetation success criteria. Regulatory criteria are specified in Rules 3.03.1(2)(c) and 3.03.1(4).
Achievement of compliance with applicable revegetation success criteria must be demonstrated for at least 2 of
the last 4 years of the minimum 10 year liability period, with year 9 being the initial allowable comparison year.
Additional information to be provided in a Phase III bond release application is addressed in the Division's
Guideline Regarding Selected Coal Mine Bond Release Issues. Success demonstration sampling for the Phase III
request areas in SL-12 was conducted in 2007 (Year 9) and 2008 (Year 10).
A new issue has come to light during the Division's review of the bond release application. For the Phase III
revegetation success standards, WFC is using the irrigated pasture reference area. This standard was not