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O <br />• Page 3 <br />Colorado Westmoreland, Inc. <br />MLRD/OSM Joint Review <br />December 2, 2980 <br /> <br />2. That the dams CWT is proposing to leave in place wi.11 become a stable <br />part of the stream channel and will not eventually breach or create <br />"nickpoints", thereby forcing the stream to readjust itself again at <br />some later date. Compliance with Rule 4.05.9(1) must also be demonstrated. <br />3. That the steep slopes and drainage patterns CWI is pr.~posing to leave <br />will form a stable portion of the natural drainage system. That is, <br />that the steep s.iopes will not gully and that tl~e tops of the steep slopes <br />will not form "nickpoints" which could create gullying upstream. If <br />gullying starts in the surface disturbed area, it could move through <br />the benched area:; causing the disturbed area to continually readjust <br />itself over a long period of time. <br />As discussed in the October 16 meeting, CWI should consider alternative <br />methods of reclaiming the disturbed area, such as locating hard sandstone <br />outcrops at or near the top of the steep slopes and routing the runoff <br />over these outcrops, and constructing plunge pools at the toe of the slope. <br />Operations Plan and SedimenC Control <br />For all roads within the permit area, cross-sections and specifications <br />for each road cut and fill embankment are needed. For cut and fill <br />embankments that are identical, a single typical cross-section will suffice. <br />Specifications should include steepness of slope for all~road cut and <br />fill embankments and an indication of the type of material the roads were <br />constructed on, i. e., unconsolidated material or rock. Compliance with new <br />performance standards must be demonstrated for all existing structures in <br />accordance with Rule 2.07.6(3). <br />For the access road connecting the portal bench to the fan bench, it appears <br />that some portions may he exceeding a pitch grade of IOo for a distance <br />longer than the limit of 300 feet pee 1,000 consecutive feet. Please submit <br />a profile diagram for this road which clearly shows all gradient changes <br />and gradient length. <br />A description, including approporate cross-sections and maps, of the measures <br />to be used to plug, case, or manage exploration holes, other bore holes, <br />wells, portals, and other openings within the proposed permit area in accordance <br />with Section 4.07 needs to be provided. <br />Provide a description of steps to be taken to comply with the NPDES permit <br />monitoring requirements. <br />Cross-sections of all ditches, including road ditches, need to be provided. <br />Fot ditches that have identical cross-sections, a typical cross-section can <br />be used. Please indicate the slope or profile of each ditch and all assumptions <br />and calculations used to determine design flows, flow depths and flow velocities. <br />y„I„4 II.. 1 <br />