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.~ C c~RUs ~ Bmpire Corporation December 30, 1991 Stephen F. Wathen Mined Land Reclamation Division 215 Centennial Building 1313 Sherman Street Denver, Colorado 80203 RE: Adequacy Response TR-20, Permit C-81-044 Dear Mr. Wathen: . s ~- ~ III IIIIIIIIIIIII III 999 P.O. Box 68 Craig, Colorado 61626 303-824-8246 ~~~~~~ L ~ ~ SAN 0 6 199? Ram, Mined Cand Cyprus Empire Corp. (CEC) has received your adequacy review and is providing the following responses to your concerns. The responses are numbered in the same order as the concerns listed in your letter. I would first like to point out that many of these same concerns have been addressed in the permit and past revisions and it is of concern to us that we should have to repeatedly justify things which the Division has already approved. Adequacy Responses 1). There is only one hydrologic soil group involved. The 5A pad is located on a previously mined area (pre SMCRA) and there is no topsoil on the disturbed site, only a mixture of subsoil and fractured sandstone. There is no change being proposed here. As shown in the approved permit Exhibit 18, the hydrologic soil group is B. As also shown in Exhibit 18, CMLRD has already approved a curve number of 82 for the disturbed site at this location. Therefore, a curve number of 84 is even more conservative. Furthermore, given the large portion of the disturbed area which is covered by gravel, rock and road base, even a smaller number is justifiable. Curve #79 represents that portion of the watershed contributing to Pond 5A-P1 which is vegetated. Here again, CEC has been conservative assuming the vegetation is only in poor condition when much is fair to good. CEC has also only placed six acres in this category when there is probably closer to 8 acres. 2). CEC has already submitted revised Map 26 with TR 20. This map clearly shows the 5A pad area, the ditch locations and the watershed boundaries to Pond 5A-P1. It also shows the existing topography. As requested, a map is enclosed showing the approximate subwatershed boundaries for individual ditches and culverts.