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2018-04-02_REVISION - C1982056
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2018-04-02_REVISION - C1982056
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Entry Properties
Last modified
4/2/2018 3:34:09 PM
Creation date
4/2/2018 12:20:57 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
4/2/2018
Doc Name
Adequacy Review Response
From
Twentymile Coal, LLC
To
DRMS
Type & Sequence
RN7
Email Name
TNL
Media Type
D
Archive
No
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Response: - The NMD Power Borehole was permitted under TR00-37 in 2000. Review of the revision submittal <br />materials does not identify a specified borehole depth, however, the reclamation cost estimate indicates 157 cy of <br />grout to seal the borehole, which is 24" in diameter. Using these two figures, a rough depth of 1,350 feet is <br />indicated. The referenced page has been revised to reflect this estimated borehole depth and copies of the revised <br />page accompany these responses for replacement in the PAP. <br />35. Section 2.05.3(5) of the Permit regarding topsoil handling at the site refers to Section 2.05.4 of the Permit to <br />address the requirements of Section 2.05.3(5) and then provides details about topsoil salvaging at some of <br />sites throughout the Permit Area. Section 2.05.4 of the Permit does not discuss the specific methods used to <br />strip topsoil. In accordance with Rule 2.05.3(5), please update this section of the permit to discuss topsoil <br />stripping methods. <br />Response: - The referenced sections address the applicable regulatory requirements for information on the areas <br />and amounts of soil material recovered and stockpiled (2.05.3(5)), and subsequently removed from stockpile and <br />replaced (2.05.4). Review of these sections indicates that the only thing possibly lacking is a description of the <br />mechanics of soil salvage, stockpiling, removal from stockpile, and replacement. A brief description addressing <br />the mechanics/methods has been added to Section 2.05.3(5) and copies of the revised text pages accompany these <br />responses for replacement in the PAP. <br />36. Rule 2.05.3(5) requires the permit narrative to specify the depth of material to be salvaged from all disturbed <br />areas. This section of the Permit only specifies the depth of soil removal from some of the disturbed areas but <br />not all of them. At this point, for the current disturbed area, the topsoil is already stripped and placed in <br />topsoil stockpiles listed on Table 49A of the Permit and depicted on Map 29 so the depth stripped is <br />irrelevant. Map 17 shows the pre -mine topsoil thickness for the permit area based on the soil mapping unit. <br />This map should be consulted to ascertain the average topsoil depth to be stripped from fitture disturbed <br />areas. Please update Section 2.05.3(5) of the permit to discuss how the depth of topsoil to be stripped at a <br />site is determined based on the soils information provided in Rule 2.04.9. <br />Response: - The soils mapping and soil unit characteristics provided by Map 17 and the Section 2.04.9 provide a <br />general reference relative to soil depths. Soil depths, however, can be highly variable dependent on topography, <br />aspect, and other factors, and as a practical matter, surface disturbances may impact multiple soil units, depending <br />on their location. TC's normal practice is to salvage all reasonably available topsoil materials, based on the visual <br />soil characteristics observed during stripping operations. The criteria for soil recovery normally include observed <br />color, texture, and plant rooting depth. When permitting information is provided to the CDRMS for any new <br />disturbance, soil recovery estimates are typically based on the soils mapping, unit descriptions, and our previous <br />(if any) field experience in the general vicinity of the proposed disturbance area. The additional text description <br />referenced in the previous response includes information on determination of soil recovery depths. <br />Rule: 2.05.3 (4)(a) -(d) <br />37. In Section 2.05-76.1 through 2.05-84, there seems to be duplicate information and outdated pages. Please <br />address the following.• <br />a. Please clarify Exhibit 8C (1). Was this structure ever built? <br />b. In the narrative (Section 2.05-76.1 through 2.05-84) for the following ponds, please insert the Exhibit <br />member and information as to the design precipitation event (for example: l0yr/24 hr or 25yr/24hr): <br />i. Pond B <br />ii. Pond C <br />iii. Pond D <br />iv. Pond E <br />V. Pond F <br />vi. Pond G <br />vii. Pond T <br />viii. FCB Treatment Facility <br />
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