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2008-06-09_REVISION - C1981038
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2008-06-09_REVISION - C1981038
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Last modified
8/24/2016 3:32:40 PM
Creation date
2/17/2009 1:19:03 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981038
IBM Index Class Name
REVISION
Doc Date
6/9/2008
Doc Name
2nd Adequacy Review
From
DRMS
To
J.E. Stover & Associates
Type & Sequence
TR48
Media Type
D
Archive
No
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'C 1981-038 TR-48 <br />2°d Adequacy Review <br />09-Jun-2008 <br />reclamation parcel (based on salvaged volume and final reclamation acreage) could be located. <br />Please provide a narrative, table, or map that specifies average replacement thickness for each <br />logical reclamation parcel to be topsoiled. <br />Narrative associated with this item in our original letter described the need for a comprehensive <br />listing of average topsoil replacement thickness for each logical reclamation parcel. This was <br />because the narrative regarding topsoil replacement was scattered through various sections, <br />different areas were apparently subject to differing replacement depths, and there was a general <br />lack of clarity. Our specific request for revised information was probably not worded as clearly as <br />it could have been. The operator's response provided specific information related to areas which <br />have not yet been topsoiled, but will be topsoiled in the upcoming reclamation project. The need <br />for a comprehensive listing of soil replacement thicknesses applicable to the various reclaimed <br />areas throughout the mine site is still warranted. A table keyed to a map or maps would probably <br />be the most concise way to present this information. <br />Please provide a comprehensive listing of the applicatble average topsoil replacement <br />thickness for each logical reclamation parcel that has been or is to be topsoiled. <br />7) The section heading at the top ofpage 59 (2.05.4(3) (a)) would appear to contain a typographical <br />error, and should be 2.05.4(2)(a). Please correct the heading. <br />The typographical error was corrected in BRL's adequacy response dated 30-Apr-2008. <br />8) The paragraph regarding rock slope entries at the bottom of Reclamation Plan page 62 is <br />apparently now out of date (since construction of the entries is no longer planned). Please amend <br />the page to delet the outdated paragraph. <br />The paragraph was deleted in BRL's adequacy response dated 30-Apr-2008. <br />9. In the first paragraph of Reclamation Plan page 66, it is stated that 0" to 9" of topsoil were <br />stripped and will be replaced on the remainder of the West Ridge disposal area... This conflicts <br />with statements elsewhere in the narrative that indicate 8 " to 9 " of topsoil were stripped and will <br />be replaced. This apparently is a typographical error, and should be corrected. A plan <br />indicating that 0 " to 9 " of topsoil would be replaced in a given location would not be meaningful <br />or enforceable, and would not comply with regulatory requirements regarding average uniform <br />replacement thickness. Please amend the referenced statement as appropriate. <br />The statement was amended in BRL's adequacy response letter dated 30-Apr-2008. <br />10. There appears to be missing narrative in our version of the reclamation plan narrative, between <br />page 66A and page 67. Our page 67 (Added 07113187/Revised 07113187/Revised 10101187) begins <br />in the middle of a sentence (the year for construction of the soil berms...), which does not flow <br />logicallyfrom the bottom ofpage 66A (Revised 10125191). Page 66B (Revised 10125191) is a <br />diagram, Figure 2.05-8 "Orchard Valley West Mine Livestock Trail ". Please provide properly <br />amended pages for the referenced section. <br />Properly amended pages were provided in BRL's adequacy response dated 30-Apr-2008. <br />11. At the Paonia Loadout Facility, approximately 40 acres were disturbed prior to enactment of
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