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i '~ 11. Drainage Control On Site -Comprehensive Drainage and Sediment Control designs and plans were prepared and have been approved as pazt of the CDMG Muting and Reclamation Permit application (refer [o Tab 13, Facilities of CDMG PAP) for surface mining operations. Given that highwall mining operations will occur within the previously disturbed surface mine pits, no additional drainage control measures are required. 12. All Roads to be Used for Project. Existing Condition of Roads. and Antiupated Improvements - RCR 53 and SCC's Mine Entrance Haut Aoad and Haul Roads A, H, I, i, and K aze presently or will be used in the future for both access to and coal haulage from the Seneca IIW Mine. The proposed highwall mining operations will continue to use the same access and haulage routes. RCR 53 was upgraded in the early 1990's from the Seneca IIW Mine to the Tie-Across Haul Road, and the County Roads Depaztment has determined that road width, geometry, and condition are comparable with general traffic and coal haulage requirements. Current road maintenance measures and schedule will continue to assure that these roads are maintained in a safe operating condition. Environmental Analysis Applicable only as specifically required b}' County Planning. Detailed informarion on soils; potential geologic, and hydrologic hazazds; and wildlife impacts is provided in the CDMG PAP. Wildfire hazards are not directly addressed by existing permit documents, however, SCC provides fire prevention and control eq~ipmeat and training as pzt of their ongoing compliance with applicable regulations of ine bline Safety and Health Adminisnation (YISH_A). Petitioner Shall Report on the Following 1. Air Pollution Potential from Facilities. Roads, and/or Equipment -Activities related to the proposed highwall mining operations that may result in air emissions include coal loading and any stockpiling activities, coal haulage operations, wind-blown dust from disturbed azeas, general site traffic, and reclamation operations. Other than vehicular emissions from mobile equipment operation and general site traffic and emissions from blasting activities, project-related air emissions will generally be limited to fugitive dust. Mining will occur underground without ventilation, so highwall mining will not generate coat dust emissions at the surface. 2. Air Pollution Controls on Facilities. Roads. and/or Equipment -Dust control measures include water sprays on the highwall miner cutterhead, periodic watering of. active operating areas and - mine roads during dry periods; grading of mi"ne roads; speed limirs~ on mine loads; use of surfactants on mine roads where warranted; and contemporaneous reclamation of tttine disturbance azeas. Potential air emissions and applicable control measures aze addressed and monitored under the terms of SCC's approved Air Emissions Permit from the Colorado Department of Public Health and Environment -Air Pollution Control Division. 3. Water Pollution Controls -The drainage control measures previously described under Item 11 of the Project Description/Nazxadve Section aze one component of a comprehensive water pollution control program for SCC's approved surface mining operations. In addition, SCC has developed, submitted, and obtained CDMG approval of a Hydrologic Monitoring Plan, Hydrologic Reclamation Plan, and analyses of Protection of Hydrologic Balance (PHB), and Probable Hydrologic Consequences (PHC). This detailed documentation is presented under Tabs 15, 16, 17, and 18 of the CDMG PAP for the Seneca IIW Mine: Water quantity and quality impact analyses for the entire Seneca IIW Mine Axea are summarized by Table 17-29, Summary of Probable Hydrologic Consequences for the Seneca IIW Mine, a copy of which is attached for reference. Highwall mining operations will not generate surface drainage flows and any ground water impacts will be similaz to those identified for the approved surface mining operations. ~`'~Rlim+aG/~C«~.fpid Ua Per~ir~ZCtll Crnj.L4PAmH i SO/$(/N iN