2010-06-21_REVISION - C1981008 ‎(2)‎

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 6/21/2010
• Doc Name: Adequacy Review No. 3
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: PR6
• Email Name: SB1
• Email Name: MLT
• Media Type: D
• Archive: No

C-1981-008
PR-06
June 21, 2010
Page 6 of 30
irrigation. The final area of reclaimed irrigated cropland will be 3.96 acres and the total irrigated
cropland field will be 4.68 acres including the area that has not been disturbed by mining.
Please use consistent acreages to describe this parcel. In Section 2.04.9 the disturbed acreage is
3.96, in Section 2.05.4(2)(d)-p 46 it is 2.06 acres and in Section 2.05.4(2)(e) it is 3.96. In
Subsection 8.1.3 of Section 2.05.4(2)(e), narrative erroneously states that the subject area would
be reclaimed to Irrigated Pasture Prime Farmland standards. Prime Farmland is to be reclaimed
to Irrigated Cropland. Please correct the error.
12.43. Resolved.
14. WFC addressed the concerns in the January 22, 2010 letter. However, in the March 16 meeting,
WFC committed to consolidate all NRCS Prime Farmland determination documentation within a
single Attachment, including descriptions of the permit area to which each document applies.
This was reiterated in the April 6 letter. The NRCS Attachment has not been provided. Please
see the comments for Rule 2.04.9 that discusses this same question.
Rule 2.05.3(3) - Mine Facilities
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. The Division asked WFC to 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. WFC partially addressed this question. The wording on page 12 is acceptable. The
wording on page 20 is not clear - please use the same wording that has been inserted in the new
paragraph on page 12.
16. The first paragraph on Page 22 of May 25, 2010 adequacy response reads, "As of the Permit
Amendment of 2009..." Please change the text to read "As of Permit Revision No. 6..."
17. The last sentence on Page 23 of May 25, 2010 adequacy response, Item 6 refers to Ponds 014
and 105. Please change the "105" to "015".
18. Roadway design plans prepared by Del-Mont Engineering have been inserted into Attachment
2.05.3(3)-8. These plans, approved by Montrose County, address the reconstruction of BB and
2700 Roads and the crossing of 2700 Road by the mine haul road. This item is resolved.
However, with the adequacy response, text providing an "Alternative Demonstration to the
Design Criteria for the Northeast Perimeter Haul Road" has been deleted from pages 33 and 34.
Pages 35-37, which previously provided details for the haul road crossing, are now blank, and
text truncated on page 34 is continued with a single phrase at the top of page 38. No explanation
has been provided for deletion of the text. A new paragraph regarding the intersection of the
Northeast Perimeter Haul Road has been added to page 45, immediately preceding the section on
"Restoration of BB Road and 2700 Road". This paragraph incorrectly states that the (Del-Mont
plans) address the NE Perimeter Haul Road, when only the crossing of 2700 Road is