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Rackcasile Company, Grassy Creek Mine ~ Adequacy Responeses ` 2 <br />• D) Vegetative cover values on newly reclaimed sites must be documented with field sampling when <br />preparing hydraulics designs. It is unjustified to indicate that the canopy cover of the reclaim is 50% <br />while the ground cover is 80% without empirical data. <br />Response: Revegeta[ion monitoring for [he Pi[ 4 reclaimed area would normally be completed per <br />[he standard revegetation monitoring schedule. Since monitoring would not normally occur for at <br />leas[ two yeazs following reseeding, Rockcas[le based estimated canopy and ground cover values <br />for hydrologic calculations on duet[ visual observation. Applicable regulations do not specify a <br />required basis for hydrologic calculations so the concept of best engineering practice is appropriate. <br />Given the stage of reclamation, [he time and expense of a separate vegetation survey [o support <br />hydrologic assumptions is no[ justifiable. While the estimated cover values utilized are not <br />represented as being enact, they are within a reasonable range of accuracy for the purpose for <br />which they were used. <br />REVISION ADEQUACY CONCERNS <br />1) TJte inslopes of Pond No. 4 are ertraordinarfly steep along the top 9 feet of the pond (44%50%). <br />This will be a problem if the pond is retained on a pem=anent basis, and contradicts the <br />recommendation found in the October 1$ 1990ACZ submittal that the pond should have 3:1 slopes. <br />The aforementioned submittal also recommended that Ditch 4-1 enter the pond on a 4:1 Jivestock <br />ramp. While the Division understands that Rockcastle is withdrawing from their request to leave Pond <br />4 as permanent at this limy I believe that the company could accommodate reconfiguration concerns <br />quite easily while regrading the overlying slope. Please modify the plan view, capacity table, and <br />stage/storage curve on the Pond No. 4 Design Plate accordingly. <br />. Response: The Pond 4 Design Map, (Map 3t-3), submitted in November, 1991, graphically <br />illustrates the proposed regraded configuration of Pond 4 following backsloping of the east slope. <br />The regraded configuration includes relatively uniform 3H:1V slopes on the east side of the pond, <br />maximum 2H:1V interior basin slopes on the south and west sides of [he pond and a uniform <br />4H:1V interior embankment slope on [he north end of the pond. All hydrologic calculators, <br />including pond capacity and stage/storage relationships are based on the illustrated configuration. <br />The entire north end of Pond 4, which is approximately 40-50 feet wide, will be established at a <br />4H:1V slope providing effective access to impounded water for both livestock and wildlife. A copy <br />of Map R3 accompanies these responses for review and reference. <br />2) Rule 4.05.6(11)(f) indicates that the com6rned upstream and downstream side slopes of the <br />embankment shall be no steeper than S:l. 1 measured both the inslope and outslope at 2:I. Please <br />modify the upslope portion of the embankment to accommodate this regulatory requirement. When <br />modtJying the design ensure that Rute 4.05.6(11)(h), the regulation on minimum top width, is in <br />compliance. <br />Response: As described in the October 8, 1990 ACZ submittal, Pond 4 is an incised pond created <br />by partial backfilling against the fmal Pi[ 4 highwall. As an incised pond, under Rule 4.05.9(4), <br />sideslopes are required to be "... stable and shall not be steeper than O.Sh:ly.". The east inslope <br />will be 3H:1V with no outslope. Similarly, the north inslope will be 4H:1V with no outslope. The <br />south inslope varies from 2H:1V to 12H:1V with no outslope and the west inslope is approximately <br />2H:1V with a 2H:1V outslope. <br />The west side of the pond appears to be the source of this concern. For the west side inslope <br />- gradients aze well within the regulatory limits for an incised pond. The existence of an outslope <br />• is a reflection of the natural terrain in this area which sloped away from the final pit highwall. Any <br />attempt to modify [he outslope would result in unnecessary disturbance of [he existing established <br />vegetation. Modification of either the inslope or outslope would offer little or no potential benefit <br />relative [o long-term pond stability. <br />ACZ Inc. ` P.O. Box 774018 "Steamboat Springs, Colorado 80477 ` (303)879-6260 <br />