2010-04-08_REVISION - C1981019 (4)

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A map or maps showing the location of facilities used to protect or enhance fish and wildlife and related environmental values will need to be included in the application, pursuant to Rule 2.05.6(2)(b). Such facilities would include stock ponds or other water developments on the reclaimed landscape. Rule 2 06 8 - Operations on Alluvial Valley Floors 18. This item is considered complete. Colowyo has provided a discussion of the mass- wasting event that occurred along the Wilson Creek. The Division will address further concerns during the technical adequacy phase. Rule 3.02.2 - Determination of Bond Amount 19. This item will be evaluated during the adequacy review. Colowyo has not provided a reclamation cost estimate for the Collom area. The Division recognizes case this is not a completeness issue given the inevitable changes to the submittal. A detailed reclamation cost estimate will need to be submitted as the adequacy phase of the review draws to a close and all major on-the-ground issues that would affect the estimate have been resolved. There are several maps associated with the reclamation cost estimate that will need to be included with the submittal of the estimate. These maps are Map 35C-Bond Calculation Map Worst Case Topography, Map 36B-Bond Calculation Map Regraded Topography and Map 40B-Bond Calculation Cross Sections. None of these were included in the PR-03 application. Rule 4.05.2 - Water Quality Standards and Effluent Limitations 20. This item remains incomplete. Rule 4.05.2(3) requires a demonstration that effluent limitations will be met for small areas. For stockpile areas as shown on Exhibit. 7, Item 23, Figure A-1 outside primary sediment control capabilities, a demonstration that effluent limitations will be met for these areas is required. Colowyo only provided a sentence in the text that a ring ditch would be cut around the topsoil stockpiles and other small areas outside the sediment control system. This is not a demonstration. For this item to be considered complete Colowyo must provide a generic SEDCAD model for topsoil storage areas that demonstrates that the ring ditches will either contain all storm runoff or treat the runoff (with the use of a rock check, straw bales, etc.) to the settleable solids limit. Rule 4.05.3 - Diversions and Conveyances of Less than One Square Mile 21. This item remains incomplete. Colowyo has stated that they will be constructing temporary diversions of surface water within the permit area during the mining operations. In the 29 March 2010 response Colowyo did provide Exhibit 7, Item 27 - Diversion Channels During Mining. The referenced item is two charts with no supporting detail or documentation. In the opening paragraph to Exhibit 7, Item 27 Colowyo states "(t)he supporting SEDCAD4 analyses and watershed maps are presented as attachments to Part A." The Division is not in possession of any Colowyo Mine C-1981-019 page 6 of 11 8 April 2010 Permit Revision 03 - Collom Permit Expansion