2011-07-11_REPORT - C1981028 (3)

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