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2009-11-23_REVISION - C1981019
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2009-11-23_REVISION - C1981019
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Last modified
8/24/2016 3:57:11 PM
Creation date
11/24/2009 10:07:21 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
11/23/2009
Doc Name
Preliminary Adequacy Review
From
Colowyo Coal Company
To
DRMS
Type & Sequence
TR82
Email Name
JRS
Media Type
D
Archive
No
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submittal was too general to meet the criteria of a verifiable plan. While Colowyo has, <br />with the submittal of TR -82, added more specificity and detail to the variable topsoil <br />replacement plan, additional specificity to ensure compliance is required. <br />Rule 2.05.4 — Reclamation Plan <br />Throughout the revised text on permit pages 2.05 -46 through 2.05 -50, Colowyo <br />discusses several generic terms including " thin topsoil ", "gradually thicker <br />topsoil ", "deeper application down slopes ", etc. While the general concept of <br />these terms is understood, they are open to the interpretation of the reader. <br />Please define and include a quantitative description of the topsoil replacement <br />zones for both the West Pit and the South Taylor Pit where these zones are <br />discussed in the permit text (for example, the second paragraph on Page 2.05 -46 <br />is the first discussion of the variable topsoil replacement zones). <br />a. For the West Pit Area, the plan will include at least two primary <br />replacement zones of defined replacement thickness range and a <br />pit -wide average. Average replacement thickness for the shallow <br />replacement zone will be no less than 4 inches, and the average <br />thickness for the two primary replacement zones will differ by at <br />least 6 inches. <br />b. For the South Taylor Area, the plan will include at least three <br />primary replacement zones of defined replacement thickness range <br />and a pit -wide average. Average replacement thickness for the <br />shallow replacement zone will be no less than 4 inches. Average <br />replacement thickness for "medium thickness" zone will exceed <br />average thickness of "shallow thickness zone" by at least 10 <br />inches. Average replacement thickness for "thick soil" zone will <br />exceed average thickness of "medium thickness" zone by at least <br />18 inches. Thick soil replacement zones will include locations <br />where slope exposure and moisture conditions would potentially be <br />favorable for establishment of aspen, chokecherry, and associated <br />species. <br />Please clarify and specify the different topsoil replacement zones and their <br />respective replacement depth in the permit text where they are addressed. Please <br />provide this text to the Division for review. <br />2. Based on the discussion of more quantitative topsoil replacement zones in <br />question 1 above, please change the "Generic Cross - Section for Topsoil <br />Replacement Depths Across a Typical Drainage ", shown on Page 2.05 -46, to <br />conform to these replacement depth zones. Please include a generic cross - section <br />for both the West Pit and the South Taylor Pit, using the pit specific replacement <br />zones in the appropriate cross - section. <br />
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