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2019-01-17_REVISION - C1982056
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2019-01-17_REVISION - C1982056
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Last modified
1/17/2019 12:31:25 PM
Creation date
1/17/2019 10:42:12 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
1/17/2019
Doc Name
Adequacy Review Response
From
Twentymile Coal, LLC
To
DRMS
Type & Sequence
TR84
Email Name
TNL
Media Type
D
Archive
No
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1. Based on your e-mail response when the Division forwarded you the CPW comment letter, <br />you indicated that the design of the pond had already taken the recommendations provided <br />by CPW into account. Please explain how the passive water treatment system was designed <br />to not trap wildlife and prohibit wildlife from exiting the ponds? Please update section <br />2.05.6(2) of the permit with this discussion. Not yet addressed. <br />Response: TC had already planned to fence the Passive Treatment System to exclude livestock and given the <br />concerns re: potential hazards to wildlife, as well as associated concerns relative to livestock or wildlife access <br />impacting the wetland plants, the exclosure fencing will be "high -fence" designed to preclude access for both <br />livestock and wildlife. The related permit text has been revised to reflect this additional consideration, and copies <br />of the revised text accompany these responses for replacement in the PAP. <br />2. The Division agrees that the exclusion of livestock from the passive water treatment system <br />would be appropriate. Does TC intend to exclude livestockfrom the passive water treatment <br />system? If so, please explain how this will be done in section 2.05.3(3) of the permit. Not yet <br />addressed. <br />Response: Please see previous response to Comment 1. <br />Items from 3rd Adequacy Review Letter <br />1. Please idents on all applicable maps the proposed pipelines, pipeline corridors, and light -use <br />road that will be required for this revision. Please ensure that all associated acreage is <br />included in the application, the reclamation plan, and the cost estimate. At this time, it is not <br />clear where the input water will be comingfrom or what new pipelines are beingproposed. <br />Response: With approval of MR15-288, pipelines were extended from the 5RT Borehole to connect with the <br />existing mine water system pipelines and a connecting pipeline was extended for future tie-in of the Passive <br />Treatment System, as initially designed. Since the Passive Treatment System location has been shifted to the <br />north and west, it will be necessary to extend the existing pipeline approximately 2,600 feet. The pipeline <br />extension has been added to the appropriate maps, and the permit text has been revised to note this component of <br />the project. Copies of the revised text and maps accompany these responses for replacement in the PAP. <br />2. Please update Map 24 with inlet pipelines. <br />Response: Please see previous response to Comment 1. <br />3. It is unclear if a cultural resources survey has been conducted for all areas of the proposed <br />disturbance at the new location. The corridor for the input pipelines is not shown. The text on <br />page 2.05-45.28 and referenced revision (MR -295) appear to be for the previous location. <br />Please ensure cultural surveys have been completed for all areas of currently proposed <br />disturbance including the proposed road and pipelines and provide appropriate references. <br />Response: Two cultural resource surveys were completed for the proposed Passive Treatment System, one in <br />2015 covering the original location and surrounding areas, and a second supplemental survey in August 2018 <br />covering those areas for the new System location not covered by the previous survey(s). Survey documentation <br />(including figures showing coverage areas) is provided in Exhibit 6Q. The surveyed areas include coverage for <br />the pipeline and associated roads. Copies of the revised text and the exhibit materials accompany these responses <br />for replacement in the PAP. <br />4. The Division spoke with the Division of Water Resources in regard to the proposed revision on <br />the mine's augmentation plan. The Division of Water Resources indicated that the mine's <br />current augmentation plan is not adequate. Please work with the Division of Water Resources <br />
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