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to address seedbed preparation, seeding, and mulching. <br /> Consideration should also be given to preserving isolated areas of <br /> established perennial vegetation, and limiting cheatgrass <br /> competition during the first growing season. <br /> 2 .05. 2 and 2.05. 3 <br /> The Division identified numerous concerns regarding operations <br /> within the North Portal mining area in the TR 20 adequacy letter <br /> dated February 13 , 1995. We have not yet received responses to <br /> that adequacy letter. Such responses must be submitted to the <br /> Division no later than September 25 . 1995. <br /> 2 .05. 3 ( 3 ) <br /> 1 . Rule changes which became effective August 1 , 1995 will require <br /> access roads used to transport coal mine waste to be redesignated <br /> as haul roads. Also, all haul and access roads not within <br /> disturbed areas will need to be certified by a P.E. Various other <br /> changes to the Division's rules pertaining to .roads may apply to <br /> roads at the mine. The rule changes and implementation procedures <br /> are summarized in the August 2, 1995 memo to operators, permittees <br /> and consultants. Please refer to the referenced memo, and follow <br /> the time frames indicated in submitting revisions to come into <br /> compliance with the amended rules. <br /> 2 . 05. 3(4) <br /> 1 . Map 6B titled, "Roadside Mine Sediment Control Plan" , depicts <br /> a 24" cmp which reduces to a 12" cmp under the Roadside Refuse Pile <br /> daylighting at Pond 9. According to the permit application, the <br /> culvert is designed for a 10 year/24 hour precipitation event with <br /> a discharge of 8. 1 cfs. This culvert appears to divert undisturbed <br /> drainage originating below the South Diversion Ditch into Pond 9. <br /> Rule 4 .09. 2(7) requires that surface runoff from above the fill be <br /> diverted away from the fill and into stabilized channels off the <br /> fill which will safely pass the runoff from a 100 year/24 hour <br /> event. <br /> In addition, it is known from site inspections that several <br /> additional culverts collect drainage from the top of the refuse <br /> pile and tie in with the culvert referenced above. These culverts <br /> are not shown on Map 6B. <br /> Several issues need to be addressed. First, it would appear that <br /> the culvert depicted on Map 6B is undersized, based on the <br /> requirements of Rule 4 .09. 2( 7) , and therefore alternative measures <br /> may need to be employed to divert flow in accordance with the rule. <br /> Second, Map 6B needs to be revised to include all culverts which <br /> are components of the drainage system for the refuse pile, along <br /> with their design specifications and supporting drainage <br /> calculations. Third, it is not apparent whether the current system <br /> of culverts is intended to be retained as a component of the <br />