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2016-11-29_REVISION - C1982056 (2)
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2016-11-29_REVISION - C1982056 (2)
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Last modified
11/30/2016 9:27:08 AM
Creation date
11/30/2016 8:31:13 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
11/29/2016
Doc Name
Adequacy Review #2
From
Twentymile Coal, LLC
To
DRMS
Type & Sequence
TR86
Email Name
JLE
DIH
Media Type
D
Archive
No
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Twentyrrule Coal, LLC. <br />Page 2 <br />11/29/2016 <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 495. <br />a. TC's Response: In reality, drill pad size and construction are similar for most <br />applications, so similar drainage design considerations would be applicable. In order to <br />directly address the question, however, TC has completed SEDCAD designs for the <br />proposed pads, which accompany these response for insertion in Exhibit 49S. Given <br />similarities in design and configuration, however, would ask the Division to consider a <br />generic drill pad drainage design in order to minimize the future need for similar <br />redundant efforts. <br />b. Division Response: According to TC's response, SEDCAD designs for the proposed <br />pads accompany the adequacy review responses. However, based on the adequacy <br />review response e-mail submitted, TC is waiting on a consulting firm to complete the <br />SEDCAD modeling. Please submit these results when they have been completed for <br />review. <br />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 />indicates all of the access roads are shown on Map 24A. Please update Map 24A or update <br />proposed Exhibit EX49S-F3 to show the location of the proposed light use road. <br />a. TC's Response: Exhibit EX49S-F3 has been revised to clarify the location of the short <br />access road required. The revised figure accompanies these responses for replacement in <br />Exhibit 49S. <br />b. Division Response: Resolved <br />Proposed Revised page 2.05-84.6 and 2.05-32.5 indicates that thickener underflow pipelines will <br />be a double HDPE pipe system in "critical areas". The cover letter for TR86 would indicate the <br />entire proposed pipeline would be a double HDPE pipe system. Please clarify, if the proposed <br />pipeline will be a double HDPE system, please revise the plan to indicate this. Or, explain what <br />criteria will be used to determine if an area is "critical" and thus warranting the installation of a <br />double HDPE system. <br />a. TC's Response: Given the location of the proposed pipeline and proximity to Foidel <br />Creek, the entire pipeline will be installed as a double -pipe system. The relevant text has <br />been reviewed and revised to reflect this consideration, and the revised text pages <br />accompany these responses for replacement/insertion in the PAP. <br />b. Division Response: Resolved <br />Thank you for forwarding the comment letter from the Colorado Parks and Wildlife (CPW) <br />regarding the proposed project. Based on this letter, CPW recommends restricting activities by <br />March 15 and that revegetation of affected areas be complete by March 1. I have confirmed with <br />Kris Middledorf with CPW that this restriction does not apply to the proposed borehole pad <br />option on the west side of RCR 27. Please update section 2.05.6(2) of the permit (page 2.05- <br />
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