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an Mathews 4 March 29. 2006 <br />Wells constructed /or the purpose of monitoring the impacts of the mine operations fall within the definition of <br />Surface Coal Mining Operations (Rule 1.04(132)(b)J, and thus need to be included within a permitted area. <br />Please amend the permit boundary as necessary to include well GW-1 and associated access within the <br />permk area, and provide reference to the documents conveying right of entry. <br />CAM -Location of GW-1 is on BLM ground. Amended Permit Boundary to incude GW-1. Changed <br />Legal Description, pg.1-T, to include GW-1. Please see attached revision form showing new permit <br />boundary acreages. Please see attached letter from the BLM conveying right of entry to be included <br />in Appendix C. Please see updated Figure 4.2-2. <br />11) Figure 2.2-3 SURFACE WATER CONTROL SYSTEMS depicts a drainage collection ditch originating at the <br />location of former diversion Culver F (watershed D-5), south of the shop building on the mine bench. The ditch <br />is shown to pass in front (east) of the shop building and along the road from the bench past the coal stockpile <br />area. Present situation on the ground is that the ditch is routed behind (south ot) the shop building, and <br />conveyed off the upper bench via an old concrete lined channel segment. The operator has indicated a <br />preference /or the existing flow route, however the steep concrete channel segment has eroded out and is no <br />longer effective. There are two alternative approached that would be acceptable; construct the ditch on the <br />ground as depicted on Figure 2.2-$ or amend the Figure in accordance with the alternate route, with speck <br />inclusion measures to be implement to stabilize the steep channel segment where the concrete lining has <br />eroded out. Please address this concern, and amend Figure 2.2-3 and applicable text as appropriate. <br />CAM -Amended Figure 2.2-3 is enclosed. The Operator will commit to repairing or replacing the <br />steep concrete channel segment. <br />12) Figure 2.2-2 SURFACE FACILITIES should be amended to delete the abandoned Culver F, and to depcct <br />the recently approved Culvert P. <br />CAM -Removed culvert "F", added culvert "P" on Figure 2.2-2. <br />13) In our copies of the application, Appendix 0, p. 1 states'This page intentionally left blank and °Replaces Small <br />Area Exemption Certification Page". We have no page 2 0(the appendix; page 3 is a haul road certification. <br />Apparently, formerpage 1 was an out-dated sedimentpond certification and form page 2 would seem to be the <br />logical location for incusion of the current sediment pond P.E. certification (performed 2005 following the <br />embankment reconstruction and primary spil/wayreplacement). Please provide a properly paginated current <br />sediment pond certification for inclusion in Appendix O. <br />CAM -Paginated 2005 Sediment Pond Certification <br />14) The reclamation cost estimate included in Table 3.7-1 is now out of date. Please review the RN-6 cost estimate <br />prepared by the Division (Enclosure 8). If you concur with the DMG estimate, please prepare a properly <br />paginated copy o/the estimate forsubmittal as a revised table 3.7-1. Please provide propersupporting <br />documentation If you believe adjustments to the OMG estimate are warranted. <br />CAM -Paginated copy of Table 3.7-1, Reclamation cost estimate <br />15) New Rule 4.15.1(5) requires inclusion of a weed management plan within the permit The McClave permit does <br />include a weed management plan in Section 4.5.14 addressing control of the county listed noxious species <br />Whitetop (hoary cress) and Canada thistle, which have been observed on the disturbed areas. The plan is <br />approximately 10 years old, and the herbicide recommendations fwcontrol of these species have evolved in <br />the interim. Also, a heavy cover of downy brome (cheatgrass), an invasive annual grass, has become <br />established on the topsoil stockpile at McClave. Use of topsoil from the stockpile containing downy brome seed <br />would likely result in the establishment of the species on reclaimed areas in the future, with negative impacts to <br />establishment of the species on reclaimed areas in the future, with negative impacts to establishment of desired <br />species. Please submit an updated weed management plan for the McClave permit, addressingspectfic <br />control measures forWhitetopand Canada thistle, and general plans forcontro/ of otherspecies listed <br />as Nox/ous by Garfield County. Also include a specific treatment plan and time frames for control of <br />downy brome. <br />CAM -Changed text on 4-73 to reflect current noxious weed control plan, specific to Canada Thistle, <br />