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TO: ROB ZUBER <br />FROM: JANET BINNS <br />SUBJECT: KEENESB <br />DATE: 6/26/2011 <br />CC: DAN HERNANDEZ <br />Permit Section 2.04.10 <br />RN6 <br />INTEROFFICE MEMORANDUM <br />I have reviewed The Keenesburg Mine permit for Permit Renewal No. 6. My comments follow: <br />1. Section 2.04.10(2) Reference Areas. This section still indicates that Valent Sand and Osgood Sand <br />reference areas are still used for this permit. The Division agrees that keeping the historic reference to <br />these reference areas has merit. However, the Division believes CEC needs to add a comment to clarify <br />that the reference area comparison was discontinued upon approval on TR37, June 15, 2006. <br />Rule 2.04.12 Prime farmland: Prior to initial disturbance SCS provided a letter documented that no prime <br />farmland was identified within the Keenesburg Mine permit area. No additional information is needed. <br />Rule 2.05.4 Reclamation plan: permit page 114a and 114b contain summaries of disturbed acreage, spoil mass <br />balance, and topsoil (topsand) mass balance. <br />2. It appears disturbed acreage, spoil mass balance, and topsoil (topsand) mass balance values were last <br />updated in 2000. These values need to be updated to the current, 2011, values, or provide a reference to <br />where the current values may be located, i.e. the Annual Reclamation Report. <br />CEC has an approved Noxious Weed Management Plan found on permit page 115c. The ARR needs to report <br />that the weed Management Plan is being implemented as approved. <br />3. Determining final revegetation standards: permit page 116. In the introductory paragraph, the reference <br />of sampling the Osgood Reference area since 1994, implies that sampling of the Osgood Reference area <br />continues. Since sampling of the Osgood reference area was terminated with the approval of TR37, it <br />would be beneficial to define the range of years the Osgood Reference area was sampled; 1994 -2006. <br />Please include the termination of Sampling of the Osgood Reference Area in the permit text in order to <br />clarify that sampling of the Osgood reference area has ceased. <br />The Division is still evaluating the Reclamation Bond in accordance with Rule 3.02.2. Currently, SL6 is still <br />under review which will affect this calculation. <br />