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REV99632
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REV99632
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Entry Properties
Last modified
8/25/2016 3:23:29 AM
Creation date
11/22/2007 12:28:54 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982057
IBM Index Class Name
Revision
Doc Date
3/14/2006
Doc Name
Adequacy Review Letter/Cost Estimate
From
DMG
To
Seneca Coal Company
Type & Sequence
PR5
Media Type
D
Archive
No
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ENCLOSURE A <br />PR-5 REVIEW OF INITIAL ADEQUACY RESPONSES <br />Response to May 27, 2005 Letter <br />Request for Withdrawal of Exhibits 20-1 and 20-I A was provided. Item Resolved. <br />Responses to Julv 11, 2005 Letter <br />1(a). SCC has properly withdrawn outdated Exhibits 20-1 and 20-1A from the <br />application package, and Tab 20 text was revised to reflect their removal. Item <br />Resolved. <br />1(b). SCC has clarified the type of disturbance that could possibly occur within the <br />"minimal disturbance areas", and has further clarified that the "minimal <br />disturbance area" acreage is not included within "disturbed area" acreage <br />projections. <br />There apparently was some confusion as to how the number of disturbed acres <br />were evaluated with respect to the reclamation cost estimate. The Division does <br />not take the number of disturbed acres from the permit application and multiply <br />by apre-determined cost per acre. The cost estimate is based on the actual <br />number of acres to be topsoiled and seeded as determined from the Annual <br />Reclamation Report and information from SCC's permit. Topsoil volumes and <br />haul distances are calculated for each topsoil stockpile. Actual costs for channel <br />maintenance are calculated based on site conditions. Therefore, the cost estimate <br />will reflect actual reclamation and maintenance costs. <br />We have a couple related requests, regarding disturbed area delineation. The <br />lower segment (approximately 275 feet) of permanent channel PM-1 is included <br />within a "minimal disturbance area" on amended Exhibit 12-2, and extends <br />outside the designated disturbed area on amended Exhibit 20-2. Likewise, <br />Sediment Pond 009 and adjacent Topsoil Stockpile KK, and Sediment Pond 015 <br />are included in "minimal disturbance areas" on amended Exhibit 12-2, and are <br />located outside the disturbed area boundary on amended Exhibit 20-2. These <br />sediment pond, stockpile, and permanent channel facilities clearly fit the <br />definition of "disturbed area". Please revise amended Exhibits 12-2 and 20-2 to <br />include the entire length of permanent channel PM-1, Sediment Ponds 009 <br />and 015, and Topsoil Stockpile I{K, within the primary disturbed area <br />boundary, and revise disturbed area acreage accounting as appropriate. <br />1(c). Disturbed area boundary on Exhibits 12-2 and 20-2 were properly amended to <br />include two slide repair areas as requested. Item Resolved. <br />
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