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ME MORANDUM <br />TO KEENESBURG FILE C1981 -028 <br />FROM: ROB ZUBER, DRMS <br />SUBJECT: KEENESBURG 2010 ANNUAL RECLAMATION REPORT (ARR) <br />DATE: 7/11/2011 <br />General <br />Coors Energy Company (CEC) submitted the 2010 Annual Hydrology and Reclamation Report for the Keenesburg Strip <br />Mine (permit C- 1981 -028) on February 28, 2011. On page 117 of the permit application package (permit), CEC has <br />committed to submitting this report by the end of February each year. The filing date of the ARR is in compliance with <br />the approved permit. The hydrology portion of this report was reviewed by the Division in March 2010. The remainder <br />of this memorandum addresses the Annual Reclamation Report (ARR) portion. <br />No new areas at the Keenesburg Strip Mine were disturbed by CEC operations in 2010. No areas were seeded, <br />interseeded, or reseeded in 2010. CEC continued to place ash and spoil cover in the south end of B pit. <br />CEC reports that in 2010 the Keenesburg mine had a total of approximately 438 disturbed acres. Of these disturbed acres, <br />251 acres had been backfilled and graded by the end of 2010. No new areas received topsoil (aka topsand) in 2010, <br />keeping the total topsoiled acreage to 251 acres. The total seeded area is 251 acres. These acreage values agree with <br />values reported in 2009 by CEC. <br />DRMS approved a Phase III bond release, SL -04, for 165.29 acres in January 2010. DRMS also approved a Phase II bond <br />release, SL -05, for 51.05 acres in October 2010. These values are reflected in the ARR form; however, they are reported <br />incorrectly. The bond release acreage should be reported in the following manner: <br />Mass Balance <br />Phase I released 229 acres <br />Phase II released 216 acres Phase III released 165 acres. <br />CEC submits results of ash disposal with the ARR. The volume of ash placed in the disposal area, and the results on <br />chemical analysis sample of bottom ash and flyash are included with the report. In 2010, CEC reports that 37,237 tons of <br />mixed flyash and bottom ash were disposed of in the B Pit at the Keenesburg Strip Mine. Two samples, one flyash <br />sample and one bottom ash sample, were analyzed for TCLP metals (leached), and TCLP mercury (leached). Results of <br />the bottom ash sample recorded Barium at 3.0 mg/L. Per the laboratory report in the ARR, the reporting limit for barium <br />is 1.0 for the reported method, and the Maximum Contaminant Level for Barium is 100 mg/L. The measured value for <br />Barium for the bottom ash sample is not identified as a concern. All other parameters analyzed for the bottom ash and <br />flyash samples were below the reporting limits for the associated analyses. <br />Review of the reported spoil mass balance (page 101) revealed no discrepancies, as indicated below (BCY = bank cubic <br />yards). <br />