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sections of the PAP should be updated accordingly, Appendix 7-12, Exhibits 7-19, 7-20, 12-1, <br />12-9, and 13-2. <br />As part of the channel reconfiguration in this azea, the upper end of PM-8 will require some <br />repair work and placement of additional riprap. Some of the riprap has washed out and the liner <br />is showing through in places. A portion of the channel in the upper reaches has been roughened <br />with a backhoe and the original configuration of the channel has been lost. Several rills have <br />formed pazallel to channel PM-8. Please repair the erosion at this location and complete the <br />necessary repairs to PM-8. <br />3. On page 12-53 of the PAP, SCC indicates that the solid waste disposal site will not be <br />final graded and reclaimed until 1998 as shown on Exhibit 13-2. This is not the case, as the solid <br />waste disposal site is still in operation. Please revise the text on page 12-53 and all appropriate <br />maps and exhibits to accurately reflect the timing for backfill and grading of the solid waste <br />disposal site. On page 12-52, SCC indicates the "Operation of the disposal site will be <br />conducted in accordance with atl local, state and federal requirements. It is not clear from this <br />discussion whether or not a permit was required from the CDPHE or any other regulatory agency <br />for the operation of this facility. Please update page 12-52 to include a discussion of the actual <br />permits required for the operation of the disposal facility. <br />The location for the Petroleum Contaminated Material Stockpile was changed with Technical <br />Revision No. 36 (TR-36). SCC has been asked to update the non-coal waste section of the PAP <br />to include information about the stockpile, including any special permitting process and <br />regulatory requirements, ultimate disposition of the stockpile, and measures taken to prevent <br />contaminated material from entering surface or groundwater. Please refer to item 10 ofthe TR- <br />36 adequacy letter dated August 2, 2004. TR-36 is pending review and approval by the Division. <br />Rule 4.11.4(2) requires a minimum of 2 feet of soil cover be placed over anon-coal waste site. <br />On page 12-53, SCC indicates that a minimum of eight feet of final backfill material will be <br />placed over the disposal site. However, there is no reclamation plan for the Petroleum <br />Contaminated Material Stockpile. In accordance with Rule 4.11.4(2), please incorporate an <br />adequate reclamation plan for both the disposal site and the Petroleum Contaminated Material <br />Stockpile site into the PAP. <br />4. From review of the PAP, it is uncleaz as to the timing for backfill and grading of the <br />facilities area including the shop, wazehouse, truck wash facility, bone yards, and offices. Please <br />update Exhibit 13-2 and all appropriate maps and text pages to include a detailed discussion and <br />timeframe for the backfill, grading, and final reclamation of the facilities area(s) located north of <br />the Wadge Impoundment. <br />5. During a meeting on April 2, 2004 at the DMG office, SCC presented a proposal for <br />sampling and evaluating reclaimed azea vegetation for Phase III Bond release. During this <br />meeting, SCC also indicated that they were planning to revise the revegetation standazds. Please <br />be advised that any changes to the approved revegetation standazds will require a technical <br />4 <br />