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<br /> <br />III IIIIIIil~llll III <br />STATE OF COL~iv~vv <br />DIVISION OF MINERALS AND GEOLOGY <br />°F <br />Department of Natural Resources ea <br />_~~ <br />M, <br />1313 Sherman 8t., Room 215 . <br />: <br />Denver, CO 80203 • <br />6 ~ <br />' <br />/ <br />Phone: (303) 866-3567 B <br />! <br />FA%: (303) 832-8106 <br />Roy Romer <br /> Governor <br /> hlichael8 Long <br />Date: January 19, 1994 Division Director <br />To: Christine Johnston <br />From: Steve Shuey ~~ <br />Re: West Elk Mine, File No. C-80-007 <br />Midterm Review -Vegetation, Soils, Wildlife <br />1 reviewed the West Elk Mine permit application as you requested. Answers to your specific <br />questions are listed below, followed by additional concerns I have identified. <br />Response to vour Questions (Memo of 1 /10/941: <br />1. Mountain Coal Company (MCC) needs to revise the wording on page 36 of Exhibit 51 to <br />clarify when monitoring will begin. Contemporaneous reclamation requires waste piles be <br />reclaimed as they are built. Mine facilities, on the other hand, are not generally reclaimed <br />until permanent cessation is requested. I believe MCC is proposing that the sampling scheme <br />will initiate in year 2 after permanent cessation. They anticipate that, by year 2 of the <br />reclamation liability period, vegetation will be "well established." <br />Recommendations.• For mine site reclamation in general, MCC's proposed vegetation studies <br />plan is okay, but needs clarification. <br />The coal refuse pile should be segregated and vegetation studies for the pile should initiate in <br />year 2 after completion of the pile. <br />Suggestion: It would benefit MCC to perform some initial vegetation studies on the currently <br />revegetated areas of the pile so they can evaluate the performance of their permanent seed <br />mix and make any necessary alterations. <br />2. Your concern over MCC's weed management plan is justified. The two paragraphs on <br />page 2.05-52 are grossly inadequate. <br />Recommendation: Send MCC a copy of our weed management guidelines and require that <br />they revise their plan before this May. Specifics should include: <br />. Herbicide types, <br />. When, where and how applied, <br />. Distance from water wherein <br />mechanical methods will be used, <br />. etc. <br /> <br />