2020-12-23_REVISION - C1981044 ‎(4)‎

• Permit No: C1981044
• IBM Index Class Name: Revision
• Doc Date: 12/23/2020
• Doc Name: Adequacy Review - Preliminary
• From: DRMS
• To: Moffat County, LLC
• Type & Sequence: TR38
• Email Name: RAR
• Email Name: JLE
• Media Type: D
• Archive: No

Miranda Kawcak
Page 3 of 4
23 December 2020
2020 December DRMS: DRMS made the following changes to the cost estimate as discussed with
Moffat County Mining (MCM), and detailed in MCMs adequacy response:
o Mulching was replaced by cover cropping with covercrop or pastureland seed mix.
o Rangeland areas will continue to receive mulch with wood straw.
o Task 62 acreage was updated in the cost estimate
o Task 63 was updated to utilize the Table 66 updated in MR
o Task 64 was also updated to utilize Table 66
o Task 39 was added for pond 9A-P2
DRMS finds that Moffat County Mining LLC, addressed this rule adequately.
There is a reference to the Amoco Pond and the Amoco Pipeline Road. DRMS is unsure where these
facilities are/were located. The reclamation of this pond constitutes task 79 and the road task 77.
4. Please clarify where these facilities are located with respect to the submitted Map 29.
2020 December DRMS: MCM provided clarification on the Amoco Pond and pipeline road. The road to
the pipeline will remain permanent. DRMS will remove Task 77 from the cost estimate.
DRMS finds that Moffat County Mining LLC, addressed this rule adequately.
5. Also, please verify if tasks 77 and 79 should be included in the cost estimate for TR38.
Currently they are included in the cost estimate provided under separate cover and associated
with this adequacy review.
2020 December DRMS: DRMS removed Task 77 from the cost estimate and Task 79 will remain until
further verification.
DRMS finds that Moffat County Mining LLC, addressed this rule adequately.
Rule: 4.05.6(13) Permanent Impoundments
October 2020 DBMS: Moffat County Mining provided Exhibit 38, comprising permanent pond
approvals for the classification of livestock water tanks with the TR38 permitting action. The
approvals, provided by the Division of Water Resources meet the requirements of the above
mentioned rule and pertains to ponds 9AP2, 9AP3, 9AP4.
6. Please inform DRMS as to the status of pond 9AP1 in the Strip Pit. Will this pond be
reclaimed or retained?
2020 December DRMS:
DRMS received records associated with Ponds 9AP3 and 9AP4 demonstrating corroboration from
the Division of Water Resources that the above mentioned ponds shall be maintained as permanent
and designated as stock tanks.
Pond 9AP1 received permanent designation in 1992 with TR21.
Pond 9AP2 was not granted permanent designation due to the vertical height exceedance and will
thus be removed from consideration as permanent in permitting action TR38.
TR38: DRMS Review of Responses to Preliminary Adequacy