2016-11-02_REVISION - C1982056 - Laserfiche WebLink

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TWENTYMILE COAL, LLC - FOIDEL CREEK MINE (C-82-056) TR16-86 WMD THICKENER UNDERFLOW BOREHOLE COMPLETENESS RESPONSE -10-11/16 1) The cover letter for TR86 indicates a cultural resource surevy is scheduled to be completed for the proposed borehole and pipeline disturbance areas. .....Once the survey has been completed, please submit the results of the survey in the form of an exhibit to the permit and update Section 2.04.4 of the permit, as appropriate. ..... Response: The required cultural survey has been completed and the survey report accompanies these responses for placement in Exhibit 6J/L. In addition, Section 2.04.4 has been reviewed and revised as appropriate to reference this cultural survey and results, and the associated revised pages accompany these responses for replacement in the PAP. The survey did not identify any cultural resource values requiring mitigation, so no additional text changes are needed. 2) Twentymile Coal submitted a revised section discussing the plugging and sealing of drillholes, wells, and pipeline abandonment. However, Section 2.05.4 of the permit was not revised to discuss the reclamation of the borehole pad and pipeline corridor to address all of the reclamation plan requirements of Rule 2.05.4(1) and (2). Please update Section 2.05.4 of the permit to comply with all the requirements of Rule 2.05.4. Response: Pages 2.05-84.5 through 84.8 discuss construction, installation, operation and reclamation of all thickener underflow boreholes (including the proposed SWMD Thickener Underflow Borehole) in some detail. These pages have been reviewed and revised to address the referenced reclamation plan requirements. The associated revised pages accompany these responses for replacement in the PAP. 3) Please evaluate the impact this project will have on fish and wildlife and make any necessary updates to Section 2.05.6(2). As Twentymile Coal has requested a variance to the stream buffer zone_for Foidel Creek, please ensure that discussion is added to Section 2.05.6(2) of the permit to explain what control measures, management techniques and any necessary monitoring will be employed. Response: The CPW has been contacted with information about the project and a request to provide a consultation letter. This letter will be forwarded to the CDRMS on receipt. The reality is that the project should have little or no impact on fish or wildlife, given that the two proposed pad alternatives are in close proximity to Routt County Road 27, and the pipeline disturbance will fall within existing disturbed areas, except for the short distance where it will tie into one of the drill -pads near the Fish Creek Road entrance. The planned disturbance does not encroach on any identified grouse leks or associated buffer zones. The application included a stream buffer zone variance request to provide some flexibility because the tie-in point with the existing thickener underflow pipeline to the Brown Palace had not been determined. It has now been determined that the tie-in will be on the north side of Haulroad C, well out of the buffer zone. If there is any project -related disturbance within the buffer zone, it will be within previously disturbed areas associated with Haulroad C. 4) As Twentymile is requesting a variance to the stream buffer zone for Foidel Creek, please update Section 2.05.6(3) of the permit to discuss what measures will be taken to protect the hydrologic balance. Specifically, this discussion must be adequate in order for the Division to make the findings required by Rule 4.05.18 for a variance to be granted.