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2018-05-31_REVISION - C1982056
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2018-05-31_REVISION - C1982056
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Entry Properties
Last modified
6/1/2018 8:30:49 AM
Creation date
6/1/2018 7:03:28 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
5/31/2018
Doc Name
Adequacy Review
From
DRMS
To
Twentymile Coal Company
Type & Sequence
RN7
Email Name
TNL
Media Type
D
Archive
No
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RN07 <br />Page 11 <br />5/30/18 <br /> <br /> <br />Response: - The Trout Creek Sandstone Test Holes were permitted in 1998 under MR98-161. The location of <br />these holes adjacent to the Old County Road is shown on Figure 21-A of the PAP. The revised Map 24 series <br />includes the labeled location of these test holes. <br /> <br />Resolved <br /> <br />34. Please revise page 65.2 to specify the depth of the 24” diameter NMD power borehole. <br /> <br />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 indicated. <br />The referenced page has been revised to reflect this estimated borehole depth and copies of the revised page <br />accompany these responses for replacement in the PAP. <br /> <br />Resolved <br /> <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 sites <br />throughout the Permit Area. Section 2.05.4 of the Permit does not discuss the specific methods used to strip <br />topsoil. In accordance with Rule 2.05.3(5), please update this section of the permit to discuss topsoil stripping <br />methods. <br /> <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 /> <br />Resolved <br /> <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 topsoil <br />stockpiles listed on Table 49A of the Permit and depicted on Map 29 so the depth stripped is irrelevant. Map <br />17 shows the pre-mine topsoil thickness for the permit area based on the soil mapping unit. This map should <br />be consulted to ascertain the average topsoil depth to be stripped from future disturbed areas. Please update <br />Section 2.05.3(5) of the permit to discuss how the depth of topsoil to be stripped at a site is determined based <br />on the soils information provided in Rule 2.04.9. <br /> <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
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