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HomeMy WebLinkAbout921818.tiff STATE OF COLORADO MINED LAND RECLAMATION SSCalif!? c.9 to w,_ Department of Natural Resources ti �` 1313 Sherman St, Room 215 l "1 9: 8 Denver,CO 80203 1792 ISM2 b R1 * ** 303 866-3567 /876 FAX 303 832-8106 CLERK Roy Romer, TO THE BC^r'D Governor Michael B Long, Division Director March 18, 1992 4n1/11- MAR 2 1992 ti Weld County Commissioners Weld Cm.=Planning Box 758 915 10th St Greeley, CO 80632 Re: Keenesburg Strip Coal Mine Permit Renewal - Permit No. C-81-028 Dear County Commissioners: Pursuant to Rule 2.08.5(3)(b) of the regulations of the Colorado Mined Land Reclamation Board for Coal Mining, you are hereby notified that the right to renew a valid, existing coal mining and reclamation permit was issued to Coors Energy Co. on November 03, 1981 for the Keenesburg Strip Mine. The surface mining operation is located approximately 4.5 miles north of Keenesburg, Colorado and is accessed from Keenesburg by Weld County Roads 18 and 59. The area is more specifically described as follows: SW 1 /4 and SE 1 /4 and NW 1 /4 of Section 25, NE 1 /4 and E 1 /2 NW 1 /4 and E 1 /2 SE 1 /4 and N 1 /2 NW 1/4 SE 1 /4 of Section 26, N 1 /2 of Section 36, Township 3 North, Range 64 West, 6th Prime Meridian. If you have any questions , please contact me. Sincerely, n E. Smith__-- .- Reclamation Specialist SES/bjw 6532G 6, C—A 9218t8 s STATE O MINED LAND RECLAMATION DIVISION -- of co<-- o Department of Natural Resources NQ``a--- 1313 Sherman St. Room 215 ' "•^ 73 F:: q: Denver.CO 80203 303 866-3567 #*1876 FAX 303 832-8106 CL a/ TO TH_ - Roy Romer, Governor Michael B Long. Division Director March 18, 1992 Weld County Clerk and Recorder Box 758 915 10th St Greeley, CO 80632 Re: Availability of "Decision to Renew a Valid, Existing Permit" for the Public Review — Keenesburg Strip Mine (C-81-028) Dear Clerk & Recorder: The Colorado Mined Land Reclamation Division requests that you maintain the enclosed "Proposed Decision and Findings of Compliance for the Keenesburg Strip Coal Mine (C-81-028) on file for public review through the public comment period. The public comment period will extend from initial publication on or about April 1 , 1992 for 30 days until May 1 , 1992. Thank you for your cooperation. Sincerely, ti �__ E. Smith (— 51 Reclamation Specialist SES/bjw Enclosure 6532G 1 L_ MAR 2 5 1992 Weld County Flanging cc: - Pk g C-, C4 4s a 3y STATE OF COLORADO MINED LAND RECLAMATION DIVISION of Department of Natural Resources ��9 1313 Sherman St., Roam 215 *:;, Denver,CO 80203 ."L; r 303 866-3567 £1876 FAX 303 832-8106 Roy Romer, Governor PROPOSED DECISION Michael B.Long, Division Director for Approval of Permit Renewal • Pursuant to C.R.S. 34-33-109(7) , the Colorado Mined Land Reclamation Division proposes to approve with conditions the renewal of a permit to conduct reclamation operations at the Keenesburg Strip Mine. This decision is based on a review of the complete and accurate application and the existing permit, including all conditions and revisions approved up to November 03, 1996. In accordance with C.R.S. 34-33-109(7)(a) , the Division makes a determination of the absence of the following criteria which would warrant that the permit not be renewed: 1 . The terms and conditions of the valid, existing permit are not being satisfactorily meet; 2. The present surface coal mining and reclamation operation is not in compliance with all requirements of the Colorado Surface Coal Mining Reclamation Act, C.R.S. 34-33-101 et sue. , and the Regulations promulgated thereunder; 3. The renewal requested substantially jeopardizes the permittee' s continuing responsibility on existing permit areas ; 4. The operator has not provided evidence that the performance bond in effect for the operation will continue in full force for the proposed period of renewal as well as any additional bond required; 5. Any additional revised or updated information as required has not been provided. Based on a preponderance of the evidence , the permit issued to Coors Energy Co. meets the requirements under the right of successive renewal . The permit application will remain a binding part of the permit. Renewal of the permit will be for a term of five (5) years. I conclude that there is no basis for denying the renewal . MINED LAND RECLAMATION DIVISION "N. Director - _ Date 65311,/bjw e Proposed Decision and Findings of Compliance for a Permit Renewal for the Keenesburg Mine C-81-028 Colorado Mined Land Reclamation Division Michael B. Long, Director Prepared By Shawn Smith Reclamation Specialist March 17, 1992 Table of Contents Page Introduction 1 Proposed Decision 3 Summary - The Review Process, 6 Description of the Environment, Description of the Operations and Reclamation Plan. Findings of the Colorado Mined Land 10 Reclamation Division Section A — Rule 2.07.6 10 Section B - Rule 4 13 I. Hydrologic Balance 13 II. Sealing of Drilled Holes and Underground Openings 14 III. Backfilling and Grading 14 IV. Revegetation 15 —i— Introduction This document is the decision package prepared by the Colorado Mined Land Reclamation Division (the Division) for the Keenesburg Mine. This document includes : 1) the proposed decision to approve with stipulations the permit renewal application; 2) a summary which includes a history of the review of the permit application , a description of the environment affected by the operation and a description of the mining and reclamation plan; and 3) the written findings of compliance the Division has made as required by the Colorado Surface Coal Mining Reclamation Act. This Findings document includes information from the November 11 , 1986 Findings of Compliance and replaces that document as a part of the approved permit. Any stipulations listed in that Findings which have been complied with are not repeated here. Stipulations to the permit which are still in effect are repeated in this Findings. Detailed information concerning the findings of compliance can be found in the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. The Division has received an application for a permit renewal to conduct surface coal mine reclamation operations only at the Keenesburg Mine. The application was submitted by Coors Energy Company. The Mine will be operated by Coors Energy Company. The mine is located on state and private lands within Weld County, Colorado. The legal description of the lands included within the permit area is: A parcel of land located in parts of Sections 25, 26, 35 and 36, Township 3 North, Range 64 West, of the Sixth Principal Meridian, County of Weld, State of Colorado, more particularly described as follows: Commencing at the northwest corner of said Section 26; thence south 0°15' 45" east along the west line of said Section 26, a distance of 600 feet, to the true point of begining; thence south 82°40'04" east, a distance of 2651 .66 feet, to the north—south centerline of said Section 26; thence north 81 °00' 14" east, a distance of 971 .31 feet; thence south 84°51 ' 18" east a distance of 1675.93 feet, to the east line of said section 26; thence north 0°36' 32" west along the east line of said Section 26, a distance of 980 feet, to the northeast corner of said Section 26; thence south 45°44' 19" east, a distance of 3718.91 feet, to the center one—quarter said Section 25; thence north 89°07' 15" east along the east—west centerline of said Section 25; a distance of 2635.63 feet, to the east one-quarter corner of said Section 25; thence south 0°32' 57" east along the east line of said Section 25, a distance of 2639.70 feet, to the south-east corner of said Section 25, thence south 0°04' 57" west along the east line of said Section 36, a distance of 2641 . 13 feet, to the east one-quarter corner of said Section 36; thence south 0°04' 57" west along the east line of said Section 36, a distance of 2641 . 13 feet, to the east one—quarter corner of said Section 36; a distance of 586. 19; thence south 89° 12' 46" west and parallel to the east—west centerline of said Section 36, a distance of 5259.48 feet, to the west line of said Section 36; thence north 0°04' 35" west along the west line of said Section 36, -1- a distance of 586. 15 feet, to the west one—quarter corner of said Section 36; thence south 89°16' 55" west along the east—west centerline of said Section 35, a distance of 400 feet; thence north 62°11 ' 52" west, a distance of 5523.83 feet, to the north—west corner of said Section 35; thence north 0°15'45" west along the west line of said Section 26, a distance of 2646.80 feet, to the west one—quarter corner of said Section 26; thence north 0°15'45" west along the west line of said Section 26, a distance of 2046.80 feet, to the true point of beginning. Containing 1498.31 acres more or less, and shown on Map Exhibit "A" together with the access road and topsoil storage areas described on Exhibits"6" and "C" . -2- Proposed Decision The Colorado Mined Land Reclamation Division proposes to approve with stipulations an application for renewal of a valid existing permit. The application was submitted by Coors Energy Company for the Keenesburg Mine. This decision is based on a finding that the operations will comply with all requirements of the Colorado State Program as found in the Colorado Surface Coal Mining Reclamation Act, C.R.S. 34-33-101 et seq. , and the Regulations promulgated pursuant to the Act. If no request for a formal hearing is made within thirty (30) days of the first publication of the issuance of this proposed decision, then this decision becomes final . Upon submittal of acceptable surety by the applicant, the permit will be issued. The permit application, all supporting documentation and any stipulations or conditions will become a binding part of the permit. -3- List of Stipulations Stipulations 1 , 2, 3, 4, 6, 7, 8, 9, 10, 11 , 12, 13, 14, 15, 16 and 18 of the original permit were resolved during the first five-year permit term. Correspondence concerning these stipulations is on file at the Division. Stipulations 5 and 17 from the previous permit are retained here. Stipulations 20, 21 , 23, 24 and 25 were added to the permit when technical revision 13 was approved and are repeated here. Stipulation No. 26 also remains in effect. Stipulations 19, 22 and 27 were resolved during the second five-year permit term. Stipulations to the Keenesburg Mine permit are as follows : STIPULATION NO. 5 THE PERMITTEE SHALL SUBMIT AN ANNUAL HYDROLOGY REPORT BY JANUARY 30 OF EACH YEAR WHICH PRESENTS AND DISCUSSES THE MONITORING DATA COLLECTED DURING THE PAST YEAR. STIPULATION NO. 17 THE PERMITTEE WILL SUBMIT TO THE DIVISION BY JANUARY 30 OF EACH YEAR AN ANNUAL REPORT WHICH INCLUDES A SUMMARY OF THE PREVIOUS CALENDAR YEAR'S PIT EXPANSION, THE CUMULATIVE TOTAL NUMBER OF ACKt5 51k1NNtU, ACRES RECLAIMED, AND DISTURBED ACRES REMAINING TO BE RECLAIMED. THE REPORT WILL ALSO INCLUDE A MAP SHOWING ACTUAL RECLAIMED TOPOGRAPHY AND A REPORT OF BACKFILLING MASS BALANCE CALCULATIONS. Technical Revision 13 set forth stipulations 20-25 and address issues of ash disposal monitoring and analysis (see attached) . ASH DISPOSAL STIPULATIONS 20. ASH MATERIAL AT THE KEENESBURG MINE MUST BE BURIED A MINIMUM OF EIGHT (8) FEET BELOW THE FINAL POST-MINING RECLAIMED SURFACE. 21 . ASH MATERIAL AT THE KEENESBURG MINE MUST BE BURIED A MINIMUM OF FIVE (5) FEET ABOVE THE PROJECTED POST-MINING WATER TABLE. 23. IN ADDITION TO THE LARAMIE-FOX HILLS MONITORING WELL INSTALLED NORTHEAST OF THE ASH DISPOSAL CELLS, A MONITORING WELL SHOULD BE INSTALLED SOUTHWEST OF THE ASH DISPOSAL AREA. ALL MONITORING WELLS MUST BE INSTALLED AND FUNCTIONING AS DESIGNED PRIOR TO DISPOSAL OF ASH AT THE MINE SITE. WELL LOCATION, DESIGN AND CONSTRUCTION TECHNIQUES MUST BE APPROVED BY THE DIVISION PRIOR TO WELL CONSTRUCTION. FREQUENCY OF MONITORING FOR ASH DISPOSAL MONITORING WELLS WILL BE MONTHLY AND PARAMETERS TO BE ANALYZED FOR INCLUDE ALL PARAMETERS SAMPLED FOR DURING THE PASTE EXTRACT ANALYSIS OF ASH SAMPLES PLUS ALL PARAMETERS INCLUDED IN SAMPLING OF QUARTERLY WATER QUALITY SAMPLES. -4- 24. EACH YEAR, A MINIMUM OF ONE (1 ) REPRESENTATIVE FLY ASH AND ONE (1 ) REPRESENTATIVE BOTTOM ASH SAMPLE SHALL BE COLLECTED FROM THE BOILERS AT THE GOLDEN POWER PLANT. LABORATORY ANALYSIS WILL CONSIST OF SATURATION EXTRACTS AND E.P. TOXICITY TEST FOR EACH SAMPLE. ADDITIONAL FLY ASH AND BOTTOM ASH SAMPLES WILL BE COLLECTED AND ANALYZED IF, AT ANY TIME, A SOURCE OF COAL IS CHANGED. RESULTS OF SATURATION EXTRACTS AND TOXICITY TESTS WILL BE SUBMITTED TO THE DIVISION WITHIN 15 DAYS OF ANALYSIS. 25. AN ANNUAL EVALUATION OF ASH DISPOSAL INCLUDING, BUT NOT LIMITED TO, SOURCE OF ASH, ASH QUALITY, TOTAL AMOUNT OF ASH DISPOSED OF, AVERAGE DEPTH OF ASH AND AERIAL EXTENT OF DISPOSAL AREAS, TRANSPORTATION AND DISPOSAL TECHNIQUES, WATER QUALITY MONITORING DATA, AND FUTURE ASH DISPOSAL SHOULD BE INCLUDED IN THE ANNUAL HYDROLOGY AND RECLAMATION REPORT. MONTHLY REPORTS CONSISTING OF SOURCE OF ASH, MATERIAL QUANTITIES DISPOSED OF, DEPTH OF ASH AND AERIAL EXTENT, WATER QUALITY MONITORING DATA, AND DISPOSAL PROBLEMS (IF ANY) SHOULD BE MADE AVAILABLE AT THE MINE OFFICE. STIPULATION NO. 26 PRIOR TO RESUMPTION OF COAL EXTRACTION OR ASSOCIATED SURFACE DISTURBANCE AT THE KEENESBURG MINE, THE PERMITTEE WILL OBTAIN APPROVAL OF A REVISION WHICH WILL PROVIDE AN UPDATED MINING AND RECLAMATION SCHEDULE AND WHICH WILL DEMONSTRATE SUFFICIENCY OF THE RECLAMATION BOND FOR THE PROJECTED WORST CASE DISTURBANCE DURING THE PERMIT TERM. -5- Summary The Review Process The Division notified the operator on January 23, 1991 that the existing permit for the Keenesburg Mine would expire on November 3, 1991 . The applicant responded on May 2, 1991 with an application for permit renewal which was deemed complete on June 4, 1991 . Public notice of the application to renew the permit was published in The New News on June 13, 1981 . On August 12, 1991 , the Division issued a letter identifying adequacy concerns in the renewal application. These concerns were addressed by the permittee in a response dated December 23, 1991 in the form of Technical Revision 25. No public comment was received regarding the application for permit renewal . The Division proposes to approved with stipulations, the application to renew the existing Keenesburg Mine Permit for reclamation only. -6- Description of the Environment The Keenesburg Mine is approximately 4.5 miles north of Keenesburg, Colorado. _ Ennis Draw, an ephemeral drainage, is located along the eastern boundary of the permit area. No stream, river, or other body of water lies within the mine site. The post-mining use of the affected land is rangeland. The permit area is located on level to gently rolling topography consisting of fine sand, which is wind-deposited material overlying weathered residual shale. The sand varies in depth from about 5 feet to 20 feet, is highly to moderately permeable, and is highly susceptible to wind erosion. For these reasons, the land capability is classified as VIe for dryland farming and IV for irrigated farming. The proposed non—irrigated site is classified as rangeland by the U.S. Department of Agriculture, Soil Conservation Service, as shown on page 37 of the permit application, general soil map of Weld County, Colorado. The land cannot support a variety of uses under existing technologies and local resources. All attempts at dryland farming on the area have been abandoned, and the damage caused by those attempts will remain evident for many decades. Otherwise, the land is moderately to well stabilized by a sandsage—prairie sandreed plant association that is used primarily for grazing by cattle in summer months . Fort Lupton, which has an average annual precipitation of 12.5 inches, provides the best estimate of precipitation at the area. Previous mining activity at the site extracted the No. 7 coal seam of the Laramie Formation. The flat—lying coal seam is overlain by 60-100 feet of overburden consisting of yellow—brown and gray to blue gray soft carbonaceous shale and clay interbedded with sand and shaley sand. At the base of the Laramie Formation is the Fox Hills member, a cross bedded gray to buff sandstone which is slightly to well cemented. Because of the low relief and deep, well drained soils, there is virtually no surface runoff Therefore, no streams springs or seeps exist in the area. All water flows subsurface through aeolian deposits to Ennis Draw, an ephemeral drainage. Ennis Draw appears to be a complex, braided, ancient stream bed that has been covered by windblown sand. It discharges several miles to the north into Box Elder Creek. Since there is no surface runoff or streams in the area, wildlife is limited to small rodents , primarily field mice, and birds with an occasional spotting of raptors such as hawks and eagles . There are no known endangered species in the area. Deer are rare as are most higher order vertebrates. -7- Description of the Operation and Reclamation Plans Since the last permit review, several revisions to the original permit have taken place. Of significant importance is the termination of all coal mining activities on the site as of December 1987. The Keenesburg site is now mainly a fly ash disposal facility for the Coors power plant in Golden. Fly ash disposal was approved by the Division through Technical Revision 13 and began in October, 1987. All stockpiled coal has been removed form the site. Mining methods previously used at the site are not listed here but can be found in the November 1986 findings document and in Section 2.05.3 of the permit application. The topsoil management plan was altered by the approval of Technical Revision 16. TR-16 allowed topsoil replacement depths on Pits A and B to be altered from three feet to a miiimum of two feet to allow for sufficient topsoil coverage of six inches over the facilities area. Temporary access roads will have a two foot top sand cover with fifteen inches cover on the long-term spoil areas . Topsoil salvage depth was also altered, from six to four feet due to current amounts available on the site. No topsoil salvaging has taken place since 1989. TR-16 clarified the revegetation criteria used in reclamation of both Pits A and B. The seed mix was altered to include more warm season species. In addition, total vegetative cover and species success criteria were established for the site. Methodology was clarified ied and a detailed annual vegetative monitoring plan submitted. Of the 424 disturbed acres at the mine site, 133 have been seeded since 1985. No revegetation has taken place since 1989 and no additional disturbance has occurred since 1987. The fly ash disposed of at the site originates from the Coor' s Power Plant in Golden and consists of residue from 80% Colowyo, 10% Maclntyre stockpile and 10% Keenesburg stockpile coal . During 1990, the third year in ash disposal operations , a total of 32,451 tons of mixed fly and bottom ash was dumped in A pit (east end) and in 1991 a total of 23,511 tons of fly ash was buried. Mass balance calculations estimate that ash disposal can continue in Pit A for another five years at present disposal rates. Filling of Pit B continues with the deepest part (north end) to be filled in the near future. The fly ash is deposited in both A and B pits at a depth no less than five feet above the projected post mine ground water table and at a minimal depth of eight feet below the original ground surface. Spoil will be replaced in pits. Excess spoils will be leveled to present a surface contour similar to the pre-mining surface . The spoil ridges will be reclaimed to a very low rolling topography prior to topsanding. The spoil will be ripped or scarified on contour. Top sand averaging 36" in depth will then be placed on the leveled spoils . The final highwall will be backfilled to AOC. The surface drainage pattern will be reestablished. Sediment ponds will be filled in and topsanded. All pit roads will be filled to AOC, scarified, topsanded, fertilized, and seeded. Power lines will be removed. Water wells will be sealed and grouted. -8- Description of the Operation and Reclamation Plans (continued) Total acreage disturbance for structures is 60 acres and includes the shop, warehouse, office and coal handling facilities. Structures will be removed and the ground top sanded with six inches of "A" horizon soil placed on top of the in situ Valent subsoil . Shale and gravel from the access roads and parking areas will be dumped in the final pit and then resanded, fertilized and then seeded. The sediment ponds , the settling basin and the drainage ditches, will then be filled, graded, scarified, fertilized, and seeded. Water Rights On July 31 , 1991 the water court referee ruled that an augmentation plan was not necessary due to the operational status of the Keenesburg Mine. Mining has ceased and the reclamation of the open pits has eliminated any exposed water; therefore, the plan for augmentation was dismissed. No protest was filed and on August 23, 1991 the judge signed the decree. A copy of the decree is found in the 1991 Annual Hydrology Report for the mine in the Appendix. -9- Findings of the Colorado Mined Land Reclamation Division for Keenesburg Mine Explanation of Findings Pursuant to Rule 2.07.6(2) of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining, and the approved state program, the Mined Land Reclamation Division or the Board must make specific written findings prior to issuance of a permit, permit renewal or permit revision. These findings are based on information made available to the Division that demonstrates that the applicant will be able to operate in compliance with the Colorado Surface Coal Mining Reclamation Act and the Regulations promulgated pursuant to the Act. The findings in the following sections required by Rule 2.07.6(2) are listed in accordance with that Rule. The findings and specific approvals required pursuant to Rule 2.07.6(2)(m) are listed in accordance with Rule 4 and are organized under subject or discipline subtitles. This findings document is updated upon permit renewal , which occurs every five years for most mines. This is the renewal findings document for the K b M; which has a year permit term. following findings were nCCt�C�UUr g Mine, rin iLn a 5 pc� u i � The following�v.. y findings reevaluated and updated if necessary to reflect changes which have occurred during the past permit term. Any stipulations from the original permit and findings document or subsequent revisions that have been totally resolved to the satisfaction of the Division, have been removed from this document. SECTION A Findings Required by Rule 2.07.6(2) . 1 . The permit application is accurate and complete. All requirements of the Act and these rules have been complied with. (2.07.6(2)(a)) . 2. Based on information contained in the permit application and other information available to the Division, the Division finds that reclamation can be feasibly accomplished at the Keenesburg Mine. (2.07.6(2)(b)) . 3. The assessment of the probable cumulative impacts of all anticipated coal mining in the general area on the hydrologic balance, as described in 2.05.6(3) , has been made by the Division. This assessment entitled "Assessment of Probable Cumulative Impact" is available for inspection at the offices of the Division. The Division finds that the operations proposed under the application have been designed to prevent damage to the hydrologic balance outside the proposed permit area. (2.07.6(2)(c) ) . -10- 4. The Division finds that the permit area is , subject to valid rights existing as of August 3, 1977, not within: a) An area designated unsuitable for surface coal mining operations (2.07.6(2)(d)( i )) ; b) An area under study for designation as unsuitable for surface coal mining operations (2.07.6(2)(d)(ii )) ; c) The boundaries of the National Park System, the National Wildlife Refuge System, the National System of Trails , the National Wilderness Preservation System, the Wild and Scenic Rivers System including rivers under study for designation, and National Recreation Areas (2.07.6(2)(d) ( iii )(A)) ; d) Three hundred feet of any public building, school , church, community or institutional building, or public park (2.07.6(2)(d)(iii )(B)) ; e) One hundred feet of a cemetary (2.07.6(2)(d)(iii )(C)) ; f) The boundaries of any National Forest unless the required finding of compatibility has been made by the Secretary of the U.S. Department of Agriculture. (2.07.6(2)(d)(iii )(D)) ; g) One hundred feet of the outside right-of-way line of any public road except where mine access or haul roads join such line, and excepting any roads for which the necessary approvals have been received, notices published, public hearing opportunities provided, and written findings made (2.07.6(2)(d)(iv)) ; h) Three hundred feet of an occupied dwelling unless a written waiver from the owner has been provided (2.07.6(2)(d)(v)) . 5. On the basis of information submitted by Coors Energy Company in the form of letter in Appendix E of the permit, the Division finds that subject to valid existing rights as of August 3, 1977, the mining operation will not adversely affect any publicly owned park or place listed on or eligible for listing in the National Register of Historic Places as determined by the State Historic Preservation Office. (2.07.6(2)(e)(i )) . 6. For this surface mining operation private mineral estate has been severed from private surface estate, therefore the documentation specified by Rule 2.03.6(2) has been provided in the form of legal documents . See Section 2.03.6 of the permit. (2.07.6(2)(f)) . 7. On the basis of evidence submitted by the applicant and received from other state and federal agencies as a result of the Section 34-33-114(3) compliance review required by the Colorado Surface Coal Mining Reclamation Act, the Division finds that Coors Energy Company does not own or control any operations which are currently in violation of any law, rule, or regulation of the United States , or any State law, rule, or regulation, or any provision of the Surface Mining Control and Reclamation Act or the Colorado Surface Coal Mining Reclamation Act. (2.07.6(2)(g)(i ) ) . -11- 8. Coors Energy Company does not control and has not controlled mining operations with a demonstrated pattern of willful violations of the Act of such nature, duration, and with such resulting irreparable damage to the environment as to indicate an intent not to comply with the provisions of the Act. (2.07.6(2)(h)) . 9. The Division finds that reclamation operations to be performed under this permit will not be inconsistent with other such operations anticipated to be performed in areas adjacent to the permit area. (2 .07.6(2)(i )) . 10. The Division currently holds $4,402,022.00 of bond for the Keenesburg Mine in the form of a Corporate Surety. The Division finds that this bond amcunt is adequate to cover reclamation liability of the site based on the projected worst case disturbance. 11 . The Division has made a negative determination for the presence of prime farmland within the permit area. The decision was based on a letter from SCS dated May 29, 1981 that demonstrates that no prime farmland mapping units are found within the permit area. See Section 2.04. 12(2) of permit (page 101 ) . (2.07.6(2)(k)) . 12. The Division has made a negative determination for the existence of alluvial valley floors within the permit area. This determination is based on information provided by the applicant which demonstrates that no alluvial valley floors exist within the mining or adjacent affected area. See I-1 and Appendix 1-2 of permit. (2.07.6(2)(k) and 2.06.8(3)(c) . 13. The Division hereby approves the post-mining land use of the operation. It was determined that rangeland designation meets the requirements of Rule 4. 16 for the permit area. (2.07.6(2)(1 )) . 14. Specific approvals have been granted or are proposed. These approvals are addressed in the following section , Section B. (2.07.6(2)(m)) . 15. The Division finds that the activities proposed by the applicant would not affect the continued existence of endangered or threatened species or result in the destruction or adverse modification of their critical habitats. (2.07.6(2)(n)) . 16. The Division has contacted the Office of Surface Mining, Reclamation Fees Branch. As of this time, Coors Energy Company, the operator is current in the payment of reclamation fees required by 30 CFR Chapter VII , subchapter R. (2.07.6(2)(0) ) . -12- SECTION B The following findings and specific approvals are required by Rule 4 I. Hydrologic Balance - Rule 4.05 A. Water Quality Standards and Effluent Limitations 1 . The applicant has demonstrated that sediment ponds and/or treatment facilities are not necessary for drainage to meet the effluent limitations of 4.05.2 and the applicable State and Federal water quality requirements for downstream receiving waters . Therefore the Division proposes to grant an exemption from these requirements. This exemption applies to the entire site due to demonstration made by Coors that there was no evidence of surface water flow on the site. (See Appendix K for study) . See permit Section 2.03.8, pages 32a and 32b and Technical Revision 23 approved 12/18/89. (4.05.2(3)(a)) . B. Surface and Ground Water Monitoring 1 . The applicant will conduct monitoring of ground water in a manner approved by the Division. The ground water monitoring plan is as follows: (4.05. 13(1 )) . Monitoring Wells The table below summarizes well designation, top of casing elevation and aquifer monitored during 1991 . Well Elev. Aquifer Location FPW 4780 Ennis Draw Mine DH96 4764 Ennis Draw Downstream from Mine DH122 4814 Ennis Draw Upstream from Mine SMW-2 4803 Reclaimed Spoil Mine AMW-1 4804 Undisturbed Mine-Downstream/Ash Overburden AMW-2 4811 Reclaimed Spoil Mine-Downstream/Ash Dry at Bottom of Ash Elevation Well sampling and water levels of subsurface water are taken from Wells SMW-2, AMW-1 , FPW, DH96 and DH122 and are sampled quarterly. AMW-2 remains dry. -13- B. Surface and Ground Water Monitoring Monitoring Wells (continued) Parameters studied are: Calcium - dissolved Iron - dissolved Magnesium - dissolved Manganese - dissolved Molybdenum - dissolved Sodium — dissolved Alkalinity, total (as CAC03 to pH 4.5) Carbonate (as C03 Hardness (as CAC03) Bicarbonate (as HCO3) pH (pH units) Specific conductance (mmhos/cm) Lead — dissolved Selenium - dissolved Total dissolved solids (at 180 degrees C) Chloride Sulfate (S04) SAR 2. There is no surface water monitoring at the Keenesburg Mine Site. On December 18, 1989 Technical Revision #23 approved the deactivation of the NPDES permit with the Department of Health concurring. For further information see pg 32 a—b, Section 2.03. 10 and Appendix I-1 of the permit. II . Sealing of Drilled Holes and Underground Openings 1 . The Division will require that each hole, well or other underground opening be capped, sealed, backfilled, or otherwise properly managed. (4.07.3) . III . Backfilling and Grading 1 . The applicant has requested additional time for backfilling and grading following coal removal in a contour strip mine. A detailed written analysis under 2.05.4(2)(c) has demonstrated that additional time is necessary. Therefore, the Division proposes to approve the additional time. (4. 14. 1 ) The variance was granted with the approval of Technical Revision No. 20 in February 28, 1989 to allow for use of the A and B pits as fly ash disposal sites . -14- IV. Revegetation 1 . The Division proposes to approve the use of introduced species in the reclamation seed mix. The applicant has submitted information which shows that the introduced species are desirable and necessary to achieve the approved post-mining land use, and are not poisonous or noxious. To convert the land to rangeland uses with warm season emphasis, two species have been introduced. They are sideoats grama and yellow Indiangrass . (4. 15.2) . 2. The Division proposes to approve the use of sorghum mulch as a means to meet soil stabilization requirements. See Minor Revisions 2 and 6. (4. 15.4) . 3. Methods to measure herbaceous cover and production, species diversity, and woody plant density are discussed in Section 2.04. 10(4) — Plant Community Measurements. For this permit, there is no minimum requirement for woody stems per acre. The Division proposes to approve of these techniques. (4. 15.7(1 )) . 4. To demonstrate that success criteria of 4. 15.8, 4. 15.9, or 4. 15. 10 have been met, the criteria will be: species diversity and herbaceous cover and production in comparison between the undisturbed reference areas and reclaimed sites. Species diversity will be considered successfully reestablished if a minimum of seven perennial species: four (4) warm season grasses, two (2) cool season grasses and one (1 ) forb are present. No one species should comprise a relative importance of greater than 40 percent or less than three percent. Herbaceous cover and production standards shall be met when the reclaimed sites exhibit at least 90 percent cover as compared to reference areas at a 90 percent confidence interval measured for two consecutive years. . The Division proposes to approve the basis for this comparison. 5. The Division proposes to approve of the reference areas which the applicant has selected based on the requirements of Rule 4. 15.7(3) . 6. The reference areas will be utilized to determine revegetation success in a manner which the Division finds acceptable. 4. 15.7(4)) . SES/ern/yjb 1305F 3/10/92 -15- Hello