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b) The surface and ground water monitoring plan should be revised to reflect the <br />currently approved parameters to be sampled as well as the sampling frequency <br />and incorporated into the permit. <br />c) The Probable Hydrological Consequence (PHC) needs to be revised to reflect <br />the concerns identified above. <br />8. Section 2.OS.3(3)(c) Haul Road. <br />a) This entire section needs revision as it has numerous errors and assumes <br />conditions that false. Paragraph 1, p. 5-11 is totally in error as the entire haul <br />road is subject to all provisions of the regulations, and in fact, unless the road is <br />county owned and maintained, the road should be included in the permit <br />boundary. <br />b) Paragraphs 4, p. 5-11 and 2 p. 5-13 states there are no alteration or relocation <br />of drainages for the haul road, however, Carbon Junction Canyon has been <br />altered and will need to be relocated in the future. <br />c) The last paragraph on p. 5-13 states two 24" culverts are located in the <br />equipment storage area, yet on the ground, three have been installed. <br />d) Surfacing of the haul road includes nothing about pavement nor about if the <br />pavement will remain after the site is reclaimed. <br />9. Section 2.OS.3(4) Ponds, Impoundments, and Diversions. <br />a) Rule 4.09.2(7) requires that surface water runoff from the area above the fill <br />be diverted away from the fill and into stabilized diversion channels designed to - <br />safely pass the 100-year, 24-hour precipitation event. The current design that has <br />the storm events passing through the underdrain was erroneously approved by the <br />Division and needs to be revised to meet present standards. A separate technical <br />revision needs to be submitted to the Division as soon as possible that addresses <br />the design of the diversions and any changes to other structures, ie ditches and <br />ponds, that may need modification due to these changes. <br />b) Paragraph 3, p. 5-20 contains the statement "that the need for a designed <br />underdrain in not applicable". is totally in error and needs to be removed. <br />10. Section 2.OS.4 Reclamation Plan, page 5-35, Terrace Reclamation. Due to the <br />steepness of the sandstone face at the North Pit area, the stability of replacing <br />four feet of cover back onto the area is in doubt. Please have your engineers <br />perform a stability analysis on the north slope (such as a Simplified Bishop) to <br />determine if the reclamation of this slope as plan can achieve a factor of safety of <br />1.3 or greater. <br />11. Table S-6 Reclamation Seed Mix. <br />a). The proposed reclamation seed mix, Permit Table S-6 revised 12/10/92, has <br />erroneously stated that 62.4 lbs./ft PIS will be applied. This should be 62.4 <br />PLS/square foot, and even then it is in excess of recommended seeding rates. <br />Midterm Review -Chimney Rock Mine~~N~Y^ Gmw._w..,...~.^~WMµ^„,„,.~„~.„.w.w.w.„.,.......m,,..,..._,.,H...October 1995 <br />