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Item 1 I. Figure 4.7-4. This figure represents final reclamation of the azea. In this regard, please <br />a) delete the "proposed" notations and highlights for the dozer slot and fill area. b) add the permit <br />boundary [Rule 2.10.1(3)]. c) revise this drawing to indicate final contours in the vicinity of the <br />sedimentation pond and topsoil piles [Rule 2.05.4(2)(c)]. d) label and dimension any permanent <br />feature, such as the roads (see Figure 4.7-3) and culverts (C2 and C6, Figure 4.6-4 and page 4- <br />57), and the Vulcan and other permanent ditches [Rule 4.24.2(2)]. This existing drawing, <br />redesignated and updated as appropriate, could be used in Annual Reclamation Reports (ARR), <br />as was done in the 1995 ARR. <br />Item 12. If not already elsewhere in the PAP, please add to Section 4.2.4.1 (page 4-10) that the <br />CMP culverts are of sufficient gauge to meet the requirements of Rule 4.03.1(4)(e)(ii). <br />Item 13. If not already elsewhere in the PAP, please add to Section 4.2.4.1 (page 4-10) that the <br />culverts are designed [o avoid plugging or collapse and erosion at inlets and outlets [Rule <br />4.04.1(4)(e)(iii)]. <br />Item 14. If not already elsewhere in the PAP, please add to Section 4.2.4.1 (page 4-10) that the <br />culverts are covered by compacted fill to a minimum depth of 1 foot [Rule 4.03.1(4)(e)(v)]. <br />Item 15. No stability analysis (factor of safety of 1.3) of the sediment pond embankment was <br />found in the PAP. If not previously accomplished, please provide such an analysis for <br />compliance with Rules 4.05.6(11)(f) [for 2 horizontal to 1 vertical embankment slopes of <br />Sedimentation Pond A (Table 4.3-6, Page 4-39 of the PAP)] and 4.05.6(11)(k). In the event one <br />is required to be developed, soil strength parameters on page 6 of Exhibit 4.3-4 are sufficient for <br />such an analysis. <br />Item 16. The elevation of the bottom of the sedimentation pond was not found in the PAP, nor <br />was the top width of the embankment. Please dimension this elevation and width on figure 4.3-6. <br />These dimensions (along with the crest elevation 5672 shown) are used to determine compliance <br />with Rule 4.05.6(11)(h), and the elevations for evaluations under Rules 4.05.6(11)(1), (j ), and (k). <br />(An as-built pond depth is provided as 12 feet.) <br />Item 17. Please update the description (PAP page 4-86) of the contents of the Annual Hydrologic <br />Report (to recognize deletion of groundwater monitoring) and include a date of submission [see <br />Rule 4.05.13(4)(c) and 4.24.4(1)]. Please also include a statement that the reports cover a <br />calendar year in-lieu-of a water year [Rule 4.05. l3(4)(b)]. <br />Item 18. Please revise Section 5.2.1 on page 5-9 [o recognize the Alluvial Valley Floor findings <br />of the Proposed Decision and Findings of Compliance for [he Coal Ridge No. 1 Mine C-84-065 <br />Permit Renewal No. 3 January 14, 1997. Alluvial Valley Floors were found associated with the <br />Colorado River, Alkali Creek and South Canyon Creek. However, due to the isolation of South <br />Canyon Creek from the mine operations, detailed information was not required. In addition, due <br />to the minimal potential of adverse impacts to the Alkali Creek alluvial valley floor, preliminary <br />information supplied was determined to be adequate. <br />Item 19. Initiation of a Phase II bond release was planned to occur before the fifth yeaz after <br />reseeding (PAP page 4-54). Revision of this statement is suggested. <br />