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Mr. David Beverlin - 2 - January 30, 1990
<br />~, Proposed page 4,3-9 states that "At the end of year 9 the southern L wag e'
<br />stockpile will become inactive." Table 4.3-2 indicates that the
<br />'"' ~ .
<br />(~ ~ South Stockpile continues to receive topsoil until year 17. Please c,.,-~.e
<br />correct this contradiction, s®~_ Cai.,,.,,t}na„7_ .~ Q~,,~i,,e a,,,_cQ
<br />_ ~ o n o;1 Sew ' (e s `"~'~`-
<br />5. Beneath the "footprint" of the south topsoil stockpile there is 'some very 4
<br />uneven ground which may potentially lead to topsoil losses or deoradation -1' l~~
<br />by mixing. In addition, no mention is made of retopsoilina this site gcy-e 5~
<br />once the stockpile is removed, Please commit to the leveling of this
<br />~~ site Pryor to stockpile construction to prevent unnecessary topsoil loss, ~I~y_i.
<br />and--the intent of ret soiling nd tQQ wh t i~ kness. Rules 4.06,3 and h~ ~~
<br />25.4(5). ~ ~'~Y'IMP~~AXINL~.--~OeSN~-~' -_r' ~~ vtec~•
<br />bk Exhibit 3.1-3 "Affected Area" and other exhibits indicate roadways that ~ ~~.I-t
<br />~~ are apparently to be used to access the south topsoil Stockpile. To ~
<br />~ clarify this vagueness, please includ escription of roads accessing
<br />the topsoil stockpiles. Rule .3(2 6Ze,~~¢.r +~, ~x 3, )- 3
<br />i
<br />~, The topsoil salvage plan does not clearly state how the equipment Iz~~ s ~~,~-
<br />operators will delineate topsoil types and depths to maximize topsoil
<br />recovery. Please describe this process in the appropriate section, ~O de'^st'~
<br />Please devise a plan to allow the Division to verify total salvage of ~j~~ei,,,,,,,~ e~
<br />~~ suitable soils during on-site inspections. One manner in which this is Colo G~ ~~~
<br />done at other o erations involves the practice of lea vi no "islands" of
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<br />undisturbed topsoil within each soil type or every five acres in the .~c iron
<br />larger soil units. After inspection the soil islands e~ up by 5~1 ~
<br />a loader or scraper and placed in a stockpile. Rule 4.06,2(b),
<br />8, In the proposed Section 3.3,2.1 the Lennox and Rider Wadae Coal seams are
<br />described as being unacceptable fuels because of high sulfur contents.
<br />However, in Section 3,3-2 it is stated that there are no toxic or acid
<br />forming materials at the Edna Mine site. Please reference the study that
<br />demonstrates these materials will not pose potential detrimental hazards
<br />to the hydrologic balance or revegetation. Rule 4,14.3(1)(a) and (cI.
<br />9. The crest of the ridge between the Oak Creek and Trout Creek drainages
<br />will be daylighted by mining in the southern section of the Moffat area
<br />as stated in proposed Section 3.4,2.1, This breach into the drainage
<br />area of Oak Creek creates the potential for hydrologic impacts on
<br />Oak Creek. Currently no monitoring of Oak Creek surface water quality is
<br />being done. P&M should either propose a plan for monitoring the
<br />Oak Creek drainage or prevent disturbed runoff from entering the
<br />Oak Creek drainage. Rule 2.04,7(2)(b)(ii),
<br />10, In the discussion of construction of the sedimentation pond for the
<br />Moffat Area in Section 4.6,1.6 no details are presented to show that the
<br />embankment will be constructed using accepted engineering practices.
<br />Specifics such as size and configuration of lifts, compaction standards,
<br />etc. should be included in this section, Rule 4,05.6(8).
<br />11, A discussion of the ph reatic surface in the sedimentation pond embankment
<br />is found in Appendix 4.6-K. However, the Division is unable to evaluate
<br />this analysis without the inclusion of assumptions and data utilized by
<br />P&d. Please include this material in your response.
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