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2020-12-09_GENERAL DOCUMENTS - C1994082
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2020-12-09_GENERAL DOCUMENTS - C1994082
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Last modified
12/16/2020 4:41:25 PM
Creation date
12/16/2020 4:27:24 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1994082
IBM Index Class Name
General Documents
Doc Date
12/9/2020
Doc Name Note
For (SL8)
Doc Name
Proposed Decision and Findings of Compliance
From
DRMS
To
Moffat County Mining, LLC
Permit Index Doc Type
Findings
Email Name
RAR
JLE
Media Type
D
Archive
No
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Phase II Bond Release <br /> Rule 3.03.1(2)(b) states: <br /> "Up to eighty-five percent of the applicable bond amount shall be released upon the establishment <br /> of vegetation supporting the approved post-mining land use and meeting the approved success <br /> standard for cover based on statistically valid data collected during a single year of the liability <br /> period." <br /> And, regarding Phase II bond release, Rule 3.03.1(3)(b) states: <br /> "No more than (60)percent of the bond shall be released so long as the lands to which the release <br /> would be applicable are contributing suspended solids to streamflow or runoff outside the permit <br /> area in excess of pre-mining levels as determined by baseline data or in excess of levels <br /> determined on adjacent non-mined areas." The Division's Guideline Regarding Selected Coal <br /> Mine Bond Release Issues suggests three methods of determining whether total suspended solids <br /> (TSS), contributions are less than or equal to premining conditions or adjacent unmined areas. <br /> For Phase 11 bond release,the approved reclamation plan calls for replacement of topsoil to a mean depth <br /> of 1.8 feet(21.6 inches) on final graded spoil. The approved replacement depth for reclaimed portions of <br /> Haul Roads A and B is 1.1 feet(13.2 inches),with a 0.5 foot (6 inches)minimum depth. Reclamation <br /> (topsoil and revegetation)of the Phase 11 areas commenced in 1997 and continued through 2013. <br /> The approved revegetation plan will achieve a primary postmining land use of livestock grazing and a <br /> secondary use of wildlife habitat. The reclamation plan establishes five primary vegetation types: <br /> 1. shrub grassland upland areas in the mine area and haul road corridor <br /> 2. upland shrub sites <br /> 3. mesic drainage tree and shrub sites <br /> 4. mesic drainage areas in the mine area <br /> 5. and alkaline lowlands in portions of the haul road corridor. <br /> To demonstrate that runoff from the reclaimed parcels results in equivalent or lesser sediment <br /> contributions as compared to baseline conditions at the mine,the Division requested that SPL utilize the <br /> Revised Universal Soil Loss Equation (RUSLE) sediment loss evaluation or a SEDCAD demonstration <br /> and submit the results to the Division. The RUSLE provides a basis for predicting the gross erosion per <br /> acre from an area on an annual basis,while SEDCAD. DRMSs' analysis of SPLs' submitted sediment <br /> demonstration is presented below in this document under the Sedimentology heading. <br /> III. OBSERVATIONS AND FINDINGS <br /> During the bond release inspection for SL8 conducted on 22 July 2020 numerous observations were <br /> documented. During the inspection, the bond release areas associated with SL8 were visually assessed <br /> for compliance with all pertinent requirements. A geospatial positioning system(GPS), and georectified <br /> maps were utilized to verify location of permanent features and to record field data relevant to specific <br /> site locations. Additionally, relevant documentation developed over the life of the operation, including <br /> information from operator annual reports and prior Division inspection reports, have also been utilized in <br /> the compliance evaluation. Observations noted in the inspection report are in agreement with the <br /> vegetation report submitted with the SL8 application. Overall,the site exhibited a diverse stand of <br /> vegetation of adequate cover to control erosion. <br /> Permit Number C1994 082 Page 9 of 15 <br />
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