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<br />Comments <br />January 8, 1982 <br />Page Three <br />understanding that the CMLRD currently interprets the <br />definition of coal processing wastes to include waste <br />materials generated during dry crushing. Therefore, <br />the regulations addressing coal processing wastes should <br />be applied to the Bear Mine. <br />12. Page 4.05-11, Section 4.05.18 - Stream Buffer Zone. <br />The Bear Permit Application notes that they will <br />encroach within 100 yards of the stream but will have <br />no effect upon it. Assuming that "encroachment" implies <br />some kind of disturbance, it is our understanding that <br />a stream buffer zone variance is required. <br />13. Figure 2.03.10-1 identifies the NPDES discharge points <br />for the existing Bear 1 and 2 mines but does not <br />identify the proposed discharge points for the area <br />included within the technical revision. <br />14. No detailed description of the vegetation reference <br />areas is given. <br />15. ARCO wishes to reserve the opportunity to further <br />comment when any additional information is submitted <br />by the Applicant. <br />Sincerely, <br />HN R. HARDIN <br />~~~~ <br />Land Manager <br />JRH:BLB/dff <br />