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TWENTYMILE COAL COMPANY -FOIDEL CREEK MINE <br />TR09-70 18-LEFT MINE WATER TRANSFER PIPELINE <br />TECHNICAL ADEQUACY RESPONSES 12/09 <br />1. Please include the sediment ponds located at the 18-Left ventilation site in Section 23 on Map 24. <br />Response: The referenced map has been revised to show the 18-Left runoff control structures. Copies <br />of the revised map accompany these responses for replacement in the PAP document. <br />2. Appendix A, revised page TR09-70, does not include costs for reclamation of the entire proposed <br />disturbance. Although TCC proposes to backfill and grade the trench incrementally as the pipeline <br />installation progresses, TCC must include costs for reclamation of the entire length of the disturbance. <br />See estimate for TR69 pipeline installation. Please include costs for backfilling and grading, and <br />topsoil replacement for the entire proposed 75.2 acre disturbance. <br />Response: The Bond Reclamation Cost Estimate has been revised to address reclamation of the entire <br />pipeline corridor. Copies of the revised estimate accompany these responses. <br />3. References to Stream Buffer Zones of 50 feet are incorrect. Rule 4.05.18 defines stream buffer <br />zones as 100 feet, or greater, of a perennial, intermittent, or ephemeral steam. Fish Creek is a <br />perennial stream. Revised pages 4.05-45.18, and 2.05-50.7 indicate that sediment control materials <br />will be used at any location where the pipeline corridor is within 50 feet of Fish Creek. Please bring <br />this distance in compliance with Rule 4.05.18 and employ sediment control measures within 100 feet of <br />Fish Creek. <br />Response: The text reference to a 50 foot off-set refers to the distance at which construction sediment <br />controls will be established if the pipeline corridor comes within that distance of either a Stream Buffer <br />Zone (perennial, intermittent, or ephemeral (drainage area greater than 1 sq. mi.) stream) or an <br />ephemeral drainage where the drianage area is less than 1 sq. mi. The text discussion on page 2.05-19 <br />details the drainage and sediment control measures and BMP's that will be used for operations with <br />Stream Buffer Zones. In reviewing the text, it was noted that a request for variance from the Stream <br />Buffer Zone requirements had not been included. The referenced text has been reviewed, and revised, <br />for clarity, and to include the variance request. Copies of the revised text pages accompany these <br />responses for replacement in the PAP document. <br />4. TCC previously provided the Division with a copy of the Special Use Permit issued by Routt <br />County, PP2009-0081 for construction of surface facilities adjacent to Routt County Road No. 27, and <br />mining beneath Routt County Roads No. 27 and 33. Please provide evidence to the Division that <br />installation of a waterline beneath Routt County Road No. 27 is consistent with the Routt County <br />Special Use Permit, or provided evidence that Routt County has approved this activity beneath the <br />public roadway. <br />Response: County zoning requirements do not address utility crossings under the County Roads. A <br />simplified permitting process with the County Road & Bridge Department involves notification and a <br />site inspection. TCC has contacted Road & Bridge, and is waiting for their follow-up call (delayed by <br />the holidays) to schedule the follow-up site inspection.