2009-09-03_REVISION - C1982056

• Permit No: C1982056
• IBM Index Class Name: REVISION
• Doc Date: 9/3/2009
• Doc Name: Adequacy Concerns & Attached Cost Estimate
• From: DRMS
• To: Twentymile Coal Company
• Type & Sequence: TR69
• Email Name: JHB
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
September 3, 2009
Mr. Jerry Nettleton
Environmental Supervisor
Twentymile Coal Company
29515 Routt County Road 27
Oak Creek, CO 80467
Re: Foidel Creek Mine, Permit No. C1982-056, TR69, adequacy concerns
Dear Mr. Nettleton:
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
The Division has reviewed Twentymile Coal Company's (TCC) application for a revision to the Foidel
Creek Permit (C 1982-056) for installation of a pipeline and an additional borehole (TR69) in order to direct
coal fines from Washplant II to 6RT mains. Please find the Division's following adequacy concerns;
1. Runoff from a portion of the pipeline disturbance, all of the borehole pad and light use road
disturbance will not report to a sediment pond. Although, TCC included these areas in the inventory
of small area exemptions (revised page 2.05-84.5) and indicated that alternate sediment control
measures, straw wattles, vegetative filters, or berms, will be used, the Division did not find any
demonstration that the alternate sediment control measures are adequate for the predicted runoff.
Please provide additional detail that the proposed alternative sediment control measures are adequate
for the expected runoff from the proposed disturbances. (Rules 4.05.2(1), (3) and (5), 4.05.5(2))
2. 4.05.18 Stream Buffer Zones. TCC has requested a variance from disturbance less than 100 feet from
Foidel Creek. TCC proposes to implement alternative sediment control measures to minimize
impacts to Foidel Creek. Please provide additional detail regarding placement location and type of
control measures to be implemented before the construction activity and after construction is
completed to assure Rule 4.05.18(1)(a) and (c) are met.
3. Revised page 2.05-32.1 has lost text previously approved during MR238 (page revised date 6/26/09).
The reference to the "dedicated propane tank for the Washplant II heaters" was eliminated from
TCC's TR69 revised page 2.05-32.1. These heaters exist on the mine surface so the text needs to be
retained. Please revise this page to retain previously approved text.
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines