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REV09464
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REV09464
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Entry Properties
Last modified
8/25/2016 1:09:57 AM
Creation date
11/21/2007 10:04:37 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
6/21/2004
Doc Name
Adequacy Response
From
Peabody Twentymile Coal Company
To
DMG
Type & Sequence
TR44
Media Type
D
Archive
No
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Byron - <br />REC~~~ ~~ <br />NN2~~4 <br />pivisian of Minerals and Geo1o9M <br />I appreciate the call re: preliminary questions from your review of TR 04-44. The following summarize our <br />phone conversations regarding your initial questions: <br />1) Discrepancy between the disturbed acreages noted in the transmittal letter and TR Application Form <br />and the descriptive text on pages 2.05 -45.3 and 205-45.4? <br />Response: The 9.2 acre total disturbance figure shown in the transmittal letter and application form is not <br />correct. In reviewing the submittal information you identified and supporting documentation, I discovered <br />that projected road disturbance had been incorrectly added to the drainage area for the shaft pad rather <br />than the actual pad disturbance area to arrive at the 9.2 acre figure. The following are the correct figures <br />for the anticipated project disturbance; <br />Shaft Pad - (280' x 280') 1.8 acres <br />Access Road Corridor - (7,100' x 30') 4.9 acres <br />It was assumed that soil materials salvaged from the road and pad disturbance areas would be <br />windrowed along the road or placed in a stockpile adjacent to the shaft pad for use in future reclamation <br />(refer to first paragraph, page 2.05-45.4). If windrowed along the road, soil materials would be stabilized <br />but would not be considered disturbance subject to sediment control. If stockpiled adjacent to the shaft <br />pad, the soil stockpile would be considered disturbance (approximately 0.5 acre), but sediment control <br />would be addressed by ASCM's (ie: a downgradient perimeter berm or ditch and gravel filter, as shown <br />on Figure 1 of the SAE demonstration). <br />If soil is stockpiled adjacent to the shaft pad, total disturbance would be approximately 7.2 acres (pad - <br />1.8 acres + road - 4.9 acres + soil stockpile - 0.5 acres). <br />2) Exhibit 5 as referenced on page 2.05-45.6? <br />Response: The reference is incorrect. The text should refer to Exhibit 8T, 18 Right Ventilation Shaft - <br />Ditch and Culvert Design and SAE Demonstration <br />3) At 4.3 acres, the SAE area exceeds the general threshold for SAE's established by mutual consent <br />between the CDMG and OSMRE? <br />Response: The 4.3 acre area used in the SAE demonstration is the SAE drainage area and includes the <br />shaft pad (1.8 acres), a possible soil stockpile (worst case - 0.5 acres), and 2.0 acres of undisturbed area. <br />Actual worst-case disturbance area for the SAE is 2.3 acres. There are numerous precedents, both for <br />Twentymile and other properties, of approved SAE's in the 0.0 to 3.0 acre range. <br />As I indicated, I will revise the appropriate pages from the TR 04-44 submittal to reflect and clarify the <br />above issues and submit them before the end of the week as a supplement to the original TR 04-44 <br />submittal. <br />In addition, you had questions about the existing approved 5.8 acre ShopM/arehouse and 4.4 acre <br />Eastern Mining District (EMD) Treatment Pond SAE'S: <br />Based on information I could find, the Shop/Warehouse SAE addresses an existing vegetated slope <br />below the ShopNVarehouse area, parts of which were disturbed and revegetated a number of years ago. <br />While the main Shop/Warehouse area drains to Pond E, a compliance review identified the subject area <br />as not having direct drainage and sediment control. Because the area was well vegetated at the time and <br />any drainage would collect along the existing railroad embankment prior to passing through the railroad <br />culvert, the CMLRD agreed that the entire area would act as a vegetative filter and that an SAE would be <br />
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