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J.E. Stover & Associates -14- May 31, 1996 Bowie No. 2 Mine Conduct of Mininq Within i0o Feet of the Right-of-Way 28. BRL requests approval to conduct mining activities within 100 feet of the historic right-of-way of old State Highway 133. Facilities such as a portion of the Haul Road Loop, sediment pond B, and the road to the gob pile are within the normal reserved buffer zone. In addition several private neighboring residences are located close to the Highway right-of-way. The haul road exits onto old State Highway 133 at a 130° immediately opposite neighboring residences. No comprehensive discussion of the probable impacts due to fugitive dust or noise, or possible safety risks due to shared use of the Highway by haul trucks and local residents is contained within the permit documents. Because BRL is requesting a specific variance, BRL should propose methods to mitigate the potential impacts and safety risks. 2.05.3(1) Ponds, Impoundments, and Diversions 29. Maps nos. 21-1 and 21-2 show many culverts which will outflow into relatively steep terrain. As explained in question No. 3 below, several of these culverts are intended to be left as permanent structures. How does the operator plan on controlling erosion at these culvert outlet locations, both during mining and after final reclamation? 30. On page 3 of Exhibit 8 of the permit application, the rainfall amount for the 25 year - 24 hour storm event is listed as 2.1 inches. In Volume V, Appendix B, a rainfall amount of 2.0 inches is used for the 25 year - 24 hour storm event. However, an examination of the NOAA Atlas 2, 1973, seems to indicate that the rainfall amount is closer to 2.2 inches. Please reconcile the use of both 2.0 and 2.1 inches of rainfall for the 25 year - 24 hour storm event, as opposed to using 2.2 inches. 31. The Division has two concerns with the curve number calculation for the burned out area, listed on page 3 of Exhibit 8. First, Table 2-2c, Runoff curve numbers for other agricultural lands, is used in the permit application calculation of the Curve number. However, the vegetation description for this area, found on page 21 of Exhibit 5, does not mention this area as being agricultural. It would seem that Table 2-2d, Runoff curve numbers for arid and semiarid rangelands would be more appropriate. Please justify the use of Table 2-2c for the burned out area. Second, a curve number of 65 is used for the burned out area. Referring to Table 2-2c, a curve number of 70 is