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<br /> <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br />John W. Hickenlooper, Governor | Mike King, Executive Director | Virginia Brannon, Director <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />RE: Foidel Creek Mine; C-1982-056; Technical Revision No. 86 (TR86) <br /> Adequacy Review No. 1 <br /> <br />Dear Mr. Nettleton: <br /> <br />The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed the above referenced <br />technical revision. The following adequacy review items will need to be addressed prior to the Division’s <br />approval of the revision. <br /> <br />2.05 – Operations and Reclamation Plan <br /> <br />1. Based on TC’s response letter to the Division’s completeness review, the variance originally <br />requested to disturb areas within the stream buffer zone may no longer be necessary because TC <br />has selected another tie-in location north of Haul Road C outside of the stream buffer zone. <br />However, the letter alludes that there may be disturbance within the stream buffer zone but it will <br />be within the disturbed areas of Haul Road C. Based on Map 24 Sheet 1, proposed to be revised <br />with this revision, the pipeline will be placed on the south side of Haul Road C. Based on Map <br />29, Sheet 4, this disturbed area along Haul Road C is partially within the Foidel Creek Stream <br />Buffer Zone at multiple location on the south side of the road. Given this, it would appear land <br />will be re-disturbed within the Foidel Creek stream buffer zone. Regardless if the area has been <br />disturbed already, TC must explain how they will protect the hydrologic balance during pipeline <br />installation, and afterward. Please revise section 2.05.6(3) (page 2.05-129) of the permit to <br />discuss what measures will be taken to comply with Rule 4.05.18(1)(a)(b) and (c). The Division <br />reviewed Exhibit 49S and 49K and could not find where TC has previously made the <br />demonstration how the pipeline disturbance will comply with Rule 4.05.18. <br /> <br />2. Exhibit 49S currently contains Drainage and Sediment Control System designs and SEDCAD <br />models to justify Alternative Sediment Control (ASC) practices for the 6RT Borehole Pad and <br />Access Road, 7RT Borehole and Pipeline and the 2MN Borehole. TC submitted design drawings <br />for Option 1 and 2 for this project but did not submit SEDCAD models to justify ASC practices. <br />Please submit these models to be included in Exhibit 49S. <br /> <br />3. Revised page 2.05-74.2 indicates that TC will install a light use road for this project. For the <br />borehole pad option east of RCR 27, it is unclear where this road will be located. Page 2.05-74.2 <br />November 15, 2016 <br /> <br />Jerry Nettleton <br />Twentymile Coal, LLC. <br />29515 Routt County Road 27 <br />Oak Creek, CO 80467 <br /> <br />