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2020-12-09_REVISION - C1994082 (11)
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2020-12-09_REVISION - C1994082 (11)
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Last modified
12/16/2020 4:41:29 PM
Creation date
12/11/2020 10:53:28 AM
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Template:
DRMS Permit Index
Permit No
C1994082
IBM Index Class Name
Revision
Doc Date
12/9/2020
Doc Name
Proposed Decision and Findings of Compliance
From
DRMS
To
Moffat County Mining, LLC
Type & Sequence
SL8
Permit Index Doc Type
Findings
Email Name
RAR
JLE
Media Type
D
Archive
No
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Adequacy Review <br /> An adequacy letter was sent to the operator on 21 August 2020 requesting as per Rule 3.03.1(3)(b)the <br /> submittal o£ <br /> 1. TSS data for sediment ponds <br /> 2. TSS data for outfalls <br /> 3. an analysis using a predictive model comparing suspended solids generated from pre mining land <br /> areas to the bond release area <br /> 4. any text and tables regarding a phase II sedimentology,hydrology and water quality information <br /> supporting the modeled sediment demonstration <br /> 5. updating of minor textural changes in the application. <br /> The operator submitted the above information addressing adequacy on 24 November 2020, satisfying <br /> DRMSs' request. No adequacy items were encountered during the inspection,however,three isolated <br /> maintenance items as follows were brought to the attention of the operator for correction and were noted <br /> in DRMS's July 2020 inspection report. These items impacted small areas and posed no significant <br /> impacts to the postmining land use. DRMS requested the operator remedy the items. The operator, <br /> as the landowner, agreed to address the items related to erosion, the removal of wire enclosures and <br /> loose netting. <br /> 1. Loose landscape netting at the top of drainage YPM13 in parcel 88 should be cleaned up. A length <br /> of down cutting above the 7550 elevation contour was noted and should be addressed. This was <br /> addressed and documented as adequately addressed in DRMS's 25 August 2020 inspection report. <br /> 2. Undercutting was observed where the YPM20 drainage meets the ditch along the road in parcel <br /> 67. Rock work was placed to mitigate the situation. <br /> 3. A gabion enclosure above Pond 12A in parcel 85 requires removal. This was addressed and <br /> documented as adequately addressed in DRMS's August 2020 inspection report. <br /> II CRITERIA AND SCHEDULE FOR BOND RELEASE <br /> Phase I Bond Release <br /> Rule 3.03.1(2)(a) states: <br /> "Up to sixty percent of the applicable bond amount shall be released when the permittee successfully <br /> completes backfilling,regrading,and drainage control in accordance with the approved reclamation <br /> plan." <br /> SPL's approved reclamation plan prepared in accordance with Rule 2.05.4 is contained in Volume 9, <br /> Tabs 19 through 21 of the permit application package (PAP). Details of the backfilling and grading <br /> plan, schedule, and post-mining topography are located in Tabs 19 and 20 of the PAP. Evaluation and <br /> inspection were based on the specific requirements of the reclamation plan and the functional <br /> requirements of the post-mining land use. No specific reclamation criteria for Phase I bond release are <br /> associated with the SL8 application as all parcels in the SL8 bond release block resulted in previous bond <br /> release requests as illustrated in Table 3 above. Phase I bond release consisting of backfilling and <br /> regrading generally took place between 1997 and 2007 and was completed within 180 days following <br /> coal removal for all parcels. <br /> Permit Number C1994 082 Page 8 of 15 <br />
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