Laserfiche WebLink
r <br />f <br />5. The ASC measures described include both "preventative" and "remedial" <br />designs. This organization can better be defined as "non-structural" and <br />"structural" from an engineering viewpoint. <br />6. From the list of ASC measures chosen, their distinction as being <br />different from ponds is what allows them to be considered an "alternate" <br />designs. It should be noted that most of the surface controls identified <br />would normally be considered in any reclamation plan irregardless of <br />whether ponds were located at the base of the disturbed area or not. <br />Preventative measures identified on page 145 and Table MP-18 include <br />revegetation, mulching, contour plowing and utilizing rocky subsoil. <br />Rule 4.05.6 of the regulations on sediment pond sizing standards allow <br />the pond storage design to reflect their inclusive use. The only true <br />alternate to a pond, as described, is a check dam. However, it should be <br />noted this is largely a distinction from ponds based on size and location <br />as the sedimentologic principles are the same. As checks require a <br />channel for construction, their location is site-specific and dependent <br />on pre- and post-mine topography. If they are artificially created in <br />areas not suited to channels, their planned use may not be warranted. <br />7. The Antelope ASC proposal uses SEDIMOT II to predict the effect of the <br />ASC measures. This model has never been verified by field data. <br />8. The exact control plan including a description of which measures at what <br />locations and the model runs were not sent to MLRD and available for <br />review. It is difficult to provide any further discussion on the <br />technical merits of the ASC plan without this information. <br />9. The proposal states results from the continuing monitoring will be used <br />to compare to the model runs. After calling personnel at Wyoming, it was <br />found this had not been done, due to a lack of runoff and sampling data. <br />Specific instrumentation and monitoring plans should be included in any <br />ASC plan approved by MLRD. <br />10. Wyoming regulations have been changed to allow for ASC following the <br />Flannery decision. Two Nerco Mines were determined sufficient as to the <br />extent for demonstrating the feasibility of ASC experimental practice <br />studies. It is uncertain at this time if one state can draw on another <br />state's experience without requiring experimental practice studies be <br />conducted before changing its own coal regulations as to sediment control. <br />/lal <br />1118E <br />