2010-01-22_REVISION - C1981008 ‎(2)‎

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 1/22/2010
• Doc Name: Preliminary Adequacy Review Letter
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: PR6
• Email Name: MLT
• Media Type: D
• Archive: No

C-1981-008
PR-06 PAR
Rule 2.05.3(33) - Mine Facilities
22-Jan-2010
Page 8 of 26
WFC has submitted certain revisions to Section 2.05.3(3). In addition to those changes
proposed, we note that items numbered 2 through 9 in this section might be more suitably
located in Section 2.05.3(4) - Ponds, Impoundments, Other Treatment Facilities and Diversions.
However, given the number of maps and internal cross references, we will not request that the
contents of the permit be rearranged with this permit revision. This is a comment only; no
response is required.
15. Page 12 of this section discusses dewatering of the mine as it relates to Pond 007. The
same subject is discussed on Page 20 with respect to Pond 011. It is our understanding
that water pumped from the pit was directed to Pond 007 until sometime in 2008, when
flows were redirected to Pond 011. In addition, both of these sections of the permit state
that a new discharge point had been applied for. WFC's updated discharge permit with
the CDPHE WQCD was subsequently issued, and incorporated into the permit with MR-
74 in August 2008.
Please revise the pit dewatering sections for Ponds 007 and 011 to be consistent with
one another; to note the month and year that dewatering transferred; and to
indicate that the discharge permit has indeed been issued.
16. The first paragraph on page 23 of this section reads, "As of the Permit Amendment of
2009..." Please change the text to read "As of Permit Revision No. 6..."
17. The last sentence of the third paragraph on Page 24 refers to Ponds 014 and 105. Please
change the "105" to "015".
18. Pages 36 and 37 of this section address the design for the mine traffic crossing of the
reclaimed 2700 Road. The detail shows an asphalt-paved surface, when what has been
constructed is a concrete-paved crossing. Please provide an explanation of the change
in roadway surface and any other changes that were made to the approved section,
along with a new professional certification.
19. Table 2.05.3(3)-3 on Page 39 gives the timing of road, ditch and utility detours and
restorations. Please update this table to provide actual years for those activities
which have already occurred and current estimates of when the remaining items
will be completed.
20. Table 2.05.3(3)-5 on Page 58 shows the timing of overhead power and buried phone
relocations. Please update this table to reflect the current status
21. Attachment 2.05.3(3)-8 contains several different documents relating to road and
structure agreements. Please provide a table of contents with this attachment,
identifying each separate document by name, date and parties. Pages 24, 28, 35 and
42 are blank in the copy received by the Division. Pages 27, 36 and 37 appear to be