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shorter time than it would take for a massive failure of the riprap that are designed by <br /> the Pader method. It is noted that the Division's observations will prove whether this is <br /> valid or not. Meanwhile, the runoff from the most critical area of the site will report to <br /> the sediment pond and the water quality of the natural stream will be protected. <br /> 64. Sedcad Results. <br /> • There are riprap, channel and culvert sizing analyses for both the 5-year and the 100- <br /> year storm events. Please confirm hydraulic structure design was done using peak flows <br /> from the 100-year design event, and not the 5-year storm. <br /> RESPONSE: As was previously noted, the 5-yr model is included for calibrating the <br /> flow of Poverty Gulch stream-bed(as it was included in the original report). The 10- <br /> yr/24-hr model was used for sizing the Sediment Pond and the minimum size of the <br /> access culvert. The 100 yr/24-hr model was used to size the channels and armoring as <br /> described in this response and included attachments (See Attachment 12). <br /> 65. Appendix 11, Reclamation Cost Model. <br /> • Page 5 indicates the cost model includes"all additions and modifications that have been <br /> made up to the date of submittal". Please be aware that additional technical revisions <br /> (i.e., TR-78 currently being reviewed by the Division) will have an impact on the bond <br /> estimate. <br /> RESPONSE. Newmont recognizes that each TR requires an update to the Reclamation <br /> Cost Model. <br /> 66. Appendix 12, ADR No. 2. <br /> • The Spill Response Plan and Spill Prevention Control and Countermeasures Plan for the <br /> Cresson Project does not appear to contain reference to or figures depicting the ADR <br /> No. 2. When and how will this be submitted to the Division? <br /> RESPONSE: The SPCC plan for the Squaw Gulch ADR was recently completed. A <br /> copy is included in Attachment 14. An updated copy of the site-wide SPCC Plan, which <br /> includes the new SG ADR SPCC Plan is on file at Newmont/CC&V administrative <br /> offices as part of the site Emergency Response Plan. <br /> ADDITIONAL COMMENTS/CONCERNS <br /> 67. Pursuant to C.R.S. 34-32-102,the Division is tasked with protecting and promoting the <br /> health, safety, and general welfare of the people of this state when related to the extraction <br /> of minerals and the reclamation of land affected by such extraction. The proximity of Teller <br /> County Road 82 to the WHEX and North Cresson (Globe Hill)pit highwalls poses potential <br /> concerns with respect to traffic safety on this road. Please coordinate with the appropriate <br /> Teller County department or office to ensure appropriate traffic safety appurtenances are <br /> considered, and if necessary, installed. <br /> RESPONSE: Comment noted. Newmont completed an update to its traffic study for the <br /> Amendment 11 activities that will be provided to Teller County and DRMS when the Teller <br /> County Mine Development Plan application is submitted. In addition, Newmont maintains <br /> close communication with Teller County and will ensure traffic controls are considered to <br /> protect the public. <br /> Page 30 of 30 <br />