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r <br />III III'I <br /> IIIIIIIIIII <br /> STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl of Natural Resources <br />1313 Sherman 51.. Room 215 rl~ <br /> <br />Denver, Colorario 80207 ~ <br />~~~ <br /> <br />Phone: 0031 866-3567 II <br />FA%:0031 8328106 <br /> DEPARTMENT OF <br /> NATURAi <br /> RESOURCE <br />September 21, 1994 Roy ROmer <br />Governor <br />Ms. Kathleen Welt Iames S. lochhead <br />Mountain Coal Company FrecunvefJire<~or <br />P. O. Box 591 michael B. Long <br />Somerset, CO 81434 ow~~~nno~reew~ <br />RE: liinor Revision No. 128 (Kid-term Review); West Elk Mine; <br />Permit No. C-80-007 <br />Dear Ms. Welt; <br />The Division has reviewed Mountain Coal Company's (MCC) responses <br />to the Division's preliminary adequacy review, dated July 19, 1994. <br />The following issues, as noted, must be reconciled prior to <br />approval of this minor revision application. The additional <br />comments are presented in the same order as the letter of July 19; <br />however, issues which have been previously resolved are not <br />included. <br />HYDROLOGY <br />4. The following addresses the SEDCAD design for the small area <br />exemption for the laydown area. <br />A. The Division believes the particle size distribution for <br />watershed 7A, described as North Fork alluvium is <br />incorrect for this area. The soil type in this area <br />according to Map 40 and 41 and referring to Exhibit 27, <br />is Fughes loam, which is a hydrologic group C soil and is <br />described as a sandy clay loam. MCC should revise the <br />model to utilize the particle size distribution for sandy <br />clay loam, rather than North Fork alluvium. <br />B. The unit hydrograph shape for watershed 7A should be <br />medium rather than slow, as the area within the watershed <br />is disturbed. <br />C. The soil erodibility factor (K) for Watershed 7A should <br />be 0.32, which represents a sandy clay loam, rather than <br />0.15 which represents sand. The model should be revised. <br />D. The control practice (CP) factor for the west side of the <br />lower storage bench, southeast of FW-1 and the east side <br />~9 ''`y `~ <br />