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C-81-019 2005 Midterm Review <br />May 5, 2005 <br />the worst case scenario used for development of the mid-term review cost estimate. <br />Item 51 This Division mid-term review cost estimate was prepazed with disposal of demolition <br />items into a pit (see the item request under Rule 4.11.4). No response by Colowyo to this item is <br />required unless the response under Rule 4.11.4 indicates that this procedure is not permitted. <br />Item 52 Map 36. The pit disturbance boundary on this map is drawn incorrectly. In other sections <br />of the PAP, Colowyo has made use of two types of disturbance (pit and facilities disturbance) <br />- boundaries, ancf~mine-plan boundary (or-limit-of-coal-extraction-boundary-).-T-he.pit disturbance <br />boundary, which allows for topsoil stripping and overburden layback associated with pit <br />development, is larger than the limit of coal extraction boundary. There aze a number of <br />regulatory topics that are not applied to features within a pit disturbance boundazy. Such items <br />aze "in-pit roads (see Rule 1.04(111) and pit-water control". Beyond the bounds of pit <br />disturbance is a disturbed azea boundary that inscribes the pit disturbance boundary and all other <br />disturbance for facilities (sediment ponds, drainage control, topsoil storage stockpiles, roads <br />(haul, access, light use), utility lines, buildings, parking areas, storage azeas, etc. Facilities <br />outside the pit disturbance boundary aze subject to a number of regulatory design and <br />performance requirements. The Division has recognized the primary crusher as being located in a <br />former pit disturbance. hi addition, the roads used to haul coal up to the cross-over and the three <br />raw coal stockpiles, and the off-road equipment pazking azeas and associated access routes, have <br />been considered as "in-pit" roads. Please revise Map 36 to define the distinctions between the <br />two types (pit and facilities) areas of disturbance. <br />Rule 4.03.3(7) <br />Item 53 Pages 4.03-3 (last paragraph) and 4.03-4 (1St sentence). The locations of Haul Roads A <br />and B, labeled as such, aze shown on Maps 22A and 22B, and the limits of the haul roads are <br />described in the text. Although light-use roads aze drawn on Maps 22A and 22B, no specific text <br />(some examples aze identified on page 4.03-4) describes their location or extents, and they are <br />not labeled. Please identify those roads not subject to the requirements for reclamation and <br />those that are subject to Phase I, II and III bond release approvals (permanent structures, <br />and those to be reclaimed, in the text on Maps 22A and 22B). These defmitions will be used <br />to support the reclamation cost estimate. Exploration roads permitted and required to be <br />reclaimed under exploration permits need not be shown on these maps or defined. <br />Rule 4.05.2(3) <br />Item 54 Page 4.05-2 lines 15 through 20. No demonstration by Colowyo was found in the PAP, <br />except for the administration and security buildings and an allusion to the Scoria Pit, for the <br />Division to grant exemptions under this rule. Reference is made (line 15) to MR-18. MR-18 <br />documentation (Colowyo letter of November 1, 1991) addressed two vegetated topsoil <br />stockpiles. The MR-18 decision document (November 6, 1991) identifies revised application <br />pages as "Add Small Area Exemptions and Maps to Exhibit No. 18." Exhibit 18 in the PAP on <br />file at the Division consists of a list of revisions, a sizing of the Gossazd Diversion Culvert, and <br />an addition of Outfal1007, and includes no such pages or map. No such descriptions or map were <br />found elsewhere during this review of the PAP. A reference to the reclamation of the Neilson <br />19 <br />