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As relatively small isolated surface disturbances, the additional disturbance required to construct ditches and <br />sedimentation ponds to intercept, route, and treat runoff from thickener underflow pad and road areas, is not warranted. <br />Similarly, for the associated temporary linear pipeline disturbances, construction of ditches and ponds to control runoff <br />is impractical. Much of the EMD Thickener Underflow Pipeline disturbance will drain naturally to existing <br />Sedimentation Ponds E, F, and G, and the majority of the drainage from pipeline areas is effectively isolated from the <br />nearest drainage (Foidel Creek) by the existing raised railroad bed. The proposed BMP's have proven effective in <br />controlling runoff and sedimentation from similar disturbances. Special design, construction, and operational measures <br />have been incorporated in the design plans to assure that there will be no discharge or mixing of mine water with <br />surface drainage. <br />Following installation of appropriate ASC's for each portion of the project disturbance, available soil materials will be <br />bladed from any new disturbance areas and temporarily windrowed or stockpiled on the upgradient edge of these <br />disturbance areas. Much of the pipeline excavation and borehole pad disturbance will occur in areas that are, or have <br />previously been, disturbed. For the remaining pipeline trench areas, consideration of soil horizon segregation must be <br />balanced with the objective of limiting overall surface disturbance. In the interest of minimizing overall surface <br />disturbance, TC proposes to not segregate and separately stockpile individual soil horizons for the pipeline trench <br />disturbance, and submits that this approach will not significantly alter soil suitability characteristics, since the <br />differences between the soil horizons is not significant over the areas to be affected by trenching. For the borehole <br />drill -pads, individual soil horizons will be segregated, if present. Generally, to avoid contamination of the windrowed <br />soil material, excavated material will be temporarily placed on the opposite side of the disturbance area. <br />For the pipeline disturbance, the excavated trench will be backfilled and regraded as the pipeline is placed, with <br />backfilling lagging behind pipeline placement consistent with pipeline fusing and installation requirements. Soil <br />materials will be replaced following completion of pipeline installation. Reseeding of the disturbed areas will be <br />completed during the first appropriate planting period following soil material replacement. When no longer needed <br />to support ongoing or future mining and related operations, the thickener underflow boreholes and associated pads <br />and roads will reclaimed by removing the surface manhole structures, plugging and sealing the boreholes consistent <br />with State Engineer requirements, cutting -off the casings below ground level and placing a permanent marker, <br />removing surfacing material from pads and roads, regrading the pads and road areas to blend with the surrounding <br />terrain and reestablish drainage, replacing soil materials, and reseeding with the appropriate approved seed mix for <br />the associated disturbance area(s). Pipelines will be abandoned in-place, with the ends of the pipelines cut-off and <br />capped below grade. <br />18LT Mine Water Transfer Pipeline (TR09-70) - As a limited, temporary, surface disturbance, construction of the <br />i 8LT Mine Water Transfer Pipeline will have minimal impacts on surface water hydrology, relative to runoff and <br />sediment contributions. It is anticipated that a maxinnun of 300 feet of pipeline trench will be open at any given time. <br />Soil removal and windrowing from this limited pipeline construction area will create a shallow (approximately 1.0 foot <br />deep) depression that, along with the trench excavation, will tend to contain any runoff from direct precipitation, as well <br />as any minor amounts of run-on from adjacent areas. Where pipeline construction approaches Fish Creek or minor <br />ephemeral/intermittent drainages, the specific BMP's and general protective measures previously detailed for the 18LT <br />Pipeline, and outlined for pipeline disturbances will be utilized to control surface runoff and sediment. Surface <br />disturbance areas associated with pipeline construction will be reclaimed concurrently with ongoing pipeline <br />construction, and regraded surface areas will be left in a roughened condition, to control runoff and erosion, until they <br />can be seeded. As a very limited disturbance area (a maximum of approximately 300 ft x 40 ft, or 0.28 acres) the active <br />pipeline construction areas meet the applicable criteria for a Small Area Exemption, and construction of full-scale <br />drainage and sediment control structures is neither needed nor justified. <br />19RT Mine Dewatering Borehole and Pipeline (TRIO -73) - During construction, and for the minor surface structures <br />that will remain during mining, drainage and sediment control for the 19RT Mine Dewatering Borehole and Pipeline <br />will be provided by Alternative Sediment Controls (ASC's) consisting of combined Best Management Practice (BMP) <br />measures. BMP's for the construction activities include: <br />• Minimizing the area of surface disturbance <br />• Scheduling of construction activities during the dry summer period <br />• Placement of staked straw wattles downgradient of all surface disturbance areas to intercept any surface runoff <br />and trap associated suspended solids <br />TR 17-87 2.05-84.8 03/14/17 <br />