2011-05-17_REPORT - C1981028

• Permit No: C1981028
• IBM Index Class Name: REPORT
• Doc Date: 5/17/2011
• Doc Name: 2010 ARR Review Memo
• From: Janet Binns
• To: Rob Zuber
• Annual Report Year: 2010
• Permit Index Doc Type: Annual Reclamation Report
• Email Name: JHB
• Email Name: RDZ
• 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
Phone: [phone]
FAX: [phone]
Interoffice Memo
May 17, 2010
To: Rob Zuber
From: Janet Bin
RE: Keenesbur Mine, 1-028, 2010 Annual Reclamation Report Responses
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
Coors Energy Company (CEC) provided the 2010 Keenesburg Mine- Annual Reclamation Report to the Division on
February 28, 2011. I have reviewed the vegetation portion of the Keenesburg Mine's 2010 Annual Reclamation
Report (ARR).
Evaluation of the 2010 Annual Report summary form finds several inconsistencies. In the "Entire life of Mine"
totals, these values need to be cumulative. If 165 acres have been approved for Phase III release, those 165 acres also
need to be shown as having been Phase I and 11 bond released as well. In other words, Phase 1 release can never be
less than Phase II or Phase III values. Looking back at the 2009 report, it appears that the Division did not have CEC
correct this discrepancy in the 2009 form either.
The Division believes that the bond release acreage should be reported in the following manner:
Phase I released 229 Phase II released 216 Phase III released 165
Please correct and resubmit the summary forms for 2009 and 2010 to reflect this reporting format.
CEC also sampled Reclamation parcel, Area 30, in 2010. The 9.68 acre Reclamation Area 30 (RA30) was seeded
with the approved permanent seed mix in 2006. Vegetation sampling in 2010 represents the fourth growing year
following seeding. CEC measured the vegetative cover on RA 30 as 52.6%. The calculated cover standard based on
the approved reclamation success formula and the measured precipitation was 36.28%. However, CEC makes the
statement that "no pests, noxious weeds, or diseases were identified during the 2010 inspections that negatively
impact the revegetation efforts." The Weld County Weed Division of Weld County Public Works identifies
Cheatgrass (Bromus tectorum) as a List C noxious weed.
Cheatgrass is a List C species on the State of Colorado Noxious weed list as well. List C species are not required
eradication, but Weld County and the State of Colorado do recommend weed control efforts and appropriate
management to try to reduce these Class C noxious weed species. The 2010 ARR states that Cheatgrass was
dominant in RA 30, contributing 23.8% cover (40.3% relative cover). Although, CEC is not requesting bond release
on this parcel, the Division does not consider noxious weeds as contributing to reclamation success. The non-
noxious plant species cover on RA 30 would remove the contribution of the noxious weed component. The 2010
vegetative cover would be 52.6% minus 23.8% cover, equaling 28.8% cover. Ninety percent of the calculated
standard 36.8% cover, equals 33.12% cover. RA 30 does not yet meet the cover standard for reclamation success,
but is developing a permanent vegetative community.
CEC should continue to implement their approved weed management plan with regards to control of Cheatgrass. No
other concerns were identified with the vegetation portion of CEC's 2010 Annual Reclamation Report for the
Keenesburg Mine.
Office of office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines