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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />Memorandum <br />April 11, 2013 <br />To: Susan Burgmaier, DRMS <br />From: Jared Ebert, DRMS i <br />RE: Bowie No. 2 Mine; C- 1996 -083 <br />Technical Revision No. 77 (TR77), Substitute Soil Analyses <br />COLORADO <br />D ] V I S I O N OF <br />RECLAMATION <br />MINING <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta Pineda <br />Director <br />As you have requested I have reviewed Technical Revision No.77 in regards to compliance to Rule 4.06.2(4) for <br />the use of overburden material as a possible substitute to topsoil. Bowie Resources, LLC (BRL) is requesting to <br />use excess coverfill material to replace and /or supplement the topsoil to be used to reclaim coal mine waste <br />stockpiles at the site. Rule 4.06.2(4)(a) indicates selected overburden material may be substituted for, or used as a <br />supplement to topsoil if the soil medium is equal to or more suitable for sustaining the vegetation than is the <br />available topsoil, and the medium is the best available in the permit area to support revegetation. This rule <br />continues to list the chemical and physical characteristics that must be analyzed to make this determination. <br />The applicant indicates in the revision application that the original topsoil material found in the gob pile #2 area is <br />comparable to the coverfill material proposed to be used as a replacement or a supplement to the salvaged topsoil. <br />In 2003 soil chemical and physical analyses of the original topsoil material was conducted and incorporated into <br />the approved permit in Exhibit 7 for the gob pile #2 and #4 area. The applicant took six samples of the coverfill <br />material and conducted a laboratory tests on the samples. The results of the soil test for the coverfill material <br />were submitted with TR77 to be included in Exhibit 7. The applicant offered a very limited analyses /comparison <br />of the original topsoil material and the proposed substitute coverfill material. Using the lab data results from the <br />200' ) soil samples and the coverfill material samples, I created Table 1 included in Appendix A using Microsoft <br />Excel® to compare the two soil materials. Appendix B includes charts created from the lab results data to aide in <br />the comparison of the soil materials. Below is a discussion of each of the parameters the Division is required to <br />analyze to determine if a soil medium can be used as a substitute or supplement to the available topsoil in <br />accordance with Rule 4.06.2(4)(a)(i). <br />Thickness of Horizons and Total Depth <br />The original soil material in the gob pile #2/4 area was highly variable, the A horizon was very shallow (< Iinch). <br />The A and B horizon were salvaged as one unit and were sampled and analyzed as one unit during the 2003 soil <br />tests. The soil depth in this area was highly variable and ranged from 0 to 30 inches (Exhibit 7, Bowie No. 2 <br />Mine PAP). The current approved reclamation plan calls for the replacement of .9 feet of topsoil material in this <br />area and 3.1 feet of coverfill material (Volume IX, Bowies No. 2 Mine PAP). During TR76, the applicant <br />requested a topsoil salvage variance in the gob pile #2 expansion area. The variance permits BRL to not salvage <br />topsoil in areas that are too rocky, too steep or too thin to salvage in this area. BRL received approval for this <br />variance and thus will likely not be able to replace the projected .9 feet of topsoil material in this area. Given this, <br />there is a need for additional soil material to make up for the shortage. There is nothing to compare for this soil <br />parameter, there is simply a deficiency of soil material and BRL would like to address this deficiency using the <br />excess coverfill material at the site. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines <br />