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19. A review of the proposed cross-sections provided on Maps 20, 20A and 20B show the <br />following changes: <br />a. Map 20, Section B-B' - TR-81 is proposing a change from Station 15000 to 17000 - <br />lowering the post-mining topography (PMT) by up to 180 feet. <br />b. Map 20A, Section E-E' - TR-81 is proposing a change from Station 15500 to <br />18000+, lowering the PMT by up to 180 feet. <br />c. Map 20B, Section A-A' - The PMT in the eastern (right-hand) portion of this section <br />is below the pre-mine elevations, but higher in the west. <br />d. Map 20B, Section B-B' - The extent and steepness of the permanent valley (West) <br />fill (Station 0+00 to 20+), are dramatically different that what was previously <br />proposed and approved. <br />e. Map 20B, Section C-C' - The extent and steepness of the permanent valley (East) fill <br />have changed only slightly with TR-81, as has the PMT. However, the PMT <br />(proposed and previously approved) is more than 200 feet lower in elevation <br />than the pre-mining topography was. <br />f. Map 20B, Section D-D' - The PMT from Station 40+00 to 82+00 is substantially <br />higher than what existed pre-mining (no change proposed with TR-81). This <br />configuration (increasing the backfill elevation above the mined-out area) seems <br />preferable to increasing the size of valley fills. <br />g. Map 20B, Section E-E' - The PMT across the pit is up to 200 lower lower than <br />the pre-mining topography. No changes are proposed with TR-81. <br />These decreases in the currently approved post-mining topography are exactly what the <br />Division is concerned about with Colowyo's proposal to increase the volume in the South <br />Taylor Fills by 10.3 million cubic yards. This concern has addressed in several of the <br />TR-81 adequacy questions (questions 2, 3, 26 and 27). Please review the currently <br />approved post-mining topography map, Map 19B, as well as their respective cross- <br />sections, Maps 20, 20A and 20B, and explain how the changes discussed above are <br />acceptable within Colowyo's currently approved variance from AOC for steep slope <br />mining for the South Taylor Pit and explain how these changes meet the definition of <br />AOC. <br />20. The final configuration for the East Taylor Fill, as shown on Map 41A - Watershed <br />Boundaries for Hydrologic Modeling, shows that the upper (southern) portion of the fill <br />will be a large, flat area. This flat area will cover approximately 110 acres. Pursuant to <br />Rule 4.09.2(7), please describe how Colowyo plans to divert the runoff from this <br />large, flat area of the pile into stabilized ditches which will safely pass the 100-year, <br />24-hour storm event. Please include this description in the text under Rule 4.09 - <br />Disposal of Excess Spoil, which begins on Page 20 (South Taylor/Lower Wilson-Rule <br />4, Page 20) in Volume 12. <br />21. The final configuration for the West Taylor Fill, as shown on Map 41A - Watershed <br />Boundaries for Hydrologic Modeling, shows that the middle portion of the fill will be a