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~ ]0/20/93 16:13 <br />~~~~ <br />P K,gNT OF l~ <br />QWa 't„ <br />~ F <br />~ 9 <br />. ~,q ,e. <br />H~ <br />$505 7662609 <br />• <br />OSM ALBUQ FO ._(1j~~001 _ <br />• III IIIIIIIIIIIIIIII <br />999 <br /> <br /> <br />United States Department of the Interior PAID IN <br />aM <br />OFFICE OF SURFACE MINING <br />Reclamation and Enforcement <br />Brooks Towers ~~, <br />1020 15th Stmt <br />Denver, Cobrado 80202 n <br />September 28, 1993 <br />MEMORANDUM <br />'-:~ ~,, <br />TO: Edzel Pugh <br />Reclamation Specialinnst, Albuquerque Field Office <br />THROUGH: Stephen F. Manager Vim' '~'`,'"~~~ <br />Acting Chief, Biological Sciences Branch - <br />FROM: Daylan W. Figgs 1-a~-~Y <br />Ecologist, Biological Sciences Hranch <br />16 <br />m ~ C <br />E `~ <br />E <br />c <br />P <br />c <br />~` ~ ^^C <br />Ui •v <br />8 ~~ 1 <br />RE: August 18, 1993 Phase III Inspection Block A; Permit <br />C-81-071 (OSM Permit'CO-0003), Mines 1, 2, and Eckman <br />Park <br />A Phase III release inspection was conducted at Cyprus Yampa <br />Valley Coal Corporations (CYCC) Mines 1, 2, and Eckman Park. <br />This report discusses potential deficiencies with the area under <br />consideration for Phase III liability release. While the <br />majority. of the report will focus on.vegetation_.issues.rai$ed.as..._ _. <br />a result of the inspection as well as from review of the release <br />application dated September 3, 1992, other areas of concern will <br />be noted and discussed. The areas of concern include vegetation <br />sampling design, erosion control/monitoring, and the retention of <br />spoil spring liability. <br />I. Vegetation Sampling Design <br />'CYCC sampled the six parcel reclamation area as a single 313.3 <br />acre release area for the purpose of demonstrating successful <br />achievement of Phase III revegetation standards. This <br />combination of area is based on the fact that all ostbining <br />landuse is pastureland and that the vegetation appears to be <br />similar between each parce~ However,' as discussed in OSM-WSC's <br />memorandum to the Albuquerque Field .Office regarding sampling of <br />discontinuous areas dated May 28, 1993, a demonstration of <br />homogeneity between discontinuous parcels must be demonstrated <br />prior to combining discontinuotis..parc~ls for the purpose of bond <br />release. CYCC made no such demonstration. A summary of the <br />parcels considered for release are'as;follows: <br />OA5-4: 5.4 acre parcel" seeded in 1976; <br />OEJ64-8: 64.8 acre parcel seeded with mixture 8 in 1980;; <br />ODJ97-3: 97.3 acre parcel. .seedeti. with mixture .3..,,Ln_19,79.;, <br />Rou-~it~o~ <br />