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•. <br />• III IIIIIIIIIIIIIIII • <br />F!-v <br />~~~~~r~,~~L~. <br />United States Department of the Interior SEP 19Cl7+986 A <br />BUREAU OF LAND MANAGEMENT ~ ~'~F~ ~'l~i1~U FIGULrIPAAT~UI` <br />Pontrose District Office L010. Ccr.. Of 1~5111E! R~SOL'fCe= <br />2465 South Townsend <br />~" "EP~'~ Montrose Colorado 81401 ~ <br />nerearo:3480 (161) ~ vEQ 17 1986 <br />Memorandum <br />To: Mel Granberg, OSM Senior Project Manager for Colorado <br />From: District Manager, Montrose <br />Subject: Adequacy Review - Permit Revision Application C-038-83 , August <br />18, 1986, BLM Lease C-37210 <br />Here are our comments on the subject application from Colorado <br />Westmoreland Inc. (CWI). <br />1. The addition of 1W Submain, the need for a change in sequencing, <br />and the increase in the number of entries required for <br />ventilation are all necessary modifications brought about by the <br />June 1st fire and should not affect mine development or coal <br />recovery. The proposed modification is in compliance with the <br />Mineral Leasing Act and all applicable 43 CFR regulations <br />including maaimum economic recovery requirements. <br />I <br />2. Section 2.04.7 lb - Last sentence, 4th paragraph states that the <br />riparian vegetation along E. Roatcap Creek does not have a high <br />value. From the standpoint of protecting the water course, the <br />soil resource, and both aquatic and terrestrial wildlife, the <br />riparian vegetation has a very high value. We request that the <br />language be changed to reflect this high value. <br />3. Appendix I, Hydrology report, section 2.3.2, page 3 <br />a. A runoff calculation summary~ia present, but detail is not <br />present that shows how value's (i.e., a CN of 60, source for <br />precipitation estimates, etch) were determined or selected <br />(at the bottom of the page).' We request this detail be shown <br />in the report, or elsewhere. <br />b. In the hydrology report, Appendix I, page 2, two methods were <br />used to determine peak flows~(Kircher, 1985, and 1T1-1, <br />McCain, 1976) for the East Roatcap Creek drainage (in order <br />to design the culvert in section 2.7 of the hydrology <br />report). The SCS Curve Number method is used in section <br />2.3.2 to determine the peak flow rate in the portal <br />sub-basins (in order to design the diversion ditch around the <br />portal bench). We request that CWI include, in Table H-1 of <br />