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2010-07-09_REVISION - C1981019 (3)
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2010-07-09_REVISION - C1981019 (3)
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Last modified
8/24/2016 4:15:28 PM
Creation date
7/12/2010 10:20:30 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
7/9/2010
Doc Name
4th Adequacy Review
From
DRMS
To
Colowyo Coal Company
Type & Sequence
TR78
Email Name
JRS
SB1
Media Type
D
Archive
No
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Technical Revision No. 78 <br />Permit No. C-1981-019 <br />July 9, 2010 <br />sump, including dewatering, sediment clean-out, inspections and any necessary repairs <br />following storm events. <br />7. This question was resolved with the 16 September 2009 Colowyo submittal. <br />8. This question was resolved with the 16 September 2009 Colowyo submittal. <br />9. Response not accepted. Colowyo has not addressed the Division's question. The question is <br />extremely important given the spoil grading schedule as presented on Map 29 and the temporary <br />nature of the ditches and sump. The Division's original adequacy question remains (as follows). <br />As stated in the general comments section above, it appears as though ditches B and C will be <br />reclaimed in 2010 and ditch A will be reclaimed in 2011. Since these temporary ditches are not <br />included on the spoil grading map, Map 29, it is not intuitive when, if or how they will be <br />reclaimed based on that map. Please detail the requested timing of the reclamation in <br />Volume 1, Section 2.05.4, Reclamation Plan. Please specify in the permit narrative how the <br />measures proposed under TR- 78 will function in combination with the reclamation <br />schedule approved under TR- 80 and Map 29. Please detail the reclamation and timing of <br />each of these temporary ditches and sumps within the reclamation schedule approved in <br />TR-80. <br />10. Response partially accepted. Neither SEDCAD model provided by Colowyo is appropriate at <br />this time for the current on the ground conditions nor the future conditions approved in TR- 80. <br />a. Response conditionally accepted. The Division interprets the Colowyo response that "the <br />model in Exhibit 7 -14P has been updated to reflect the approved curve numbers from <br />TR-78" to mean that "the model in Exhibit 7-14R has been updated to reflect the <br />approved curve numbers from TR-73". If this is not correct, please advise. <br />b. Response accepted. Area F is now included. <br />C. Given other issues associated with current and future Prospect Pond modeling, this issue <br />will be deferred. <br />d. Response not accepted. The Prospect Pond model needs to reflect the worst-case <br />disturbance for the Prospect drainage given the reclamation schedule provided on Map 29 <br />( updated with TR-80). The currently approved worst-case disturbance modeling <br />(contained in Exhibit 7PP) is based on the old reclamation schedule for the East Pit. <br />11. Response not accepted. Colowyo has not addressed the Division's concern from the third <br />adequacy review letter. Colowyo vaguely states that "... to address the long term stability of the <br />Prospect watershed, a new PMT will need to be completed. Colowyo hopes to complete this <br />within the next year...". This response is inadequate and does not address the Division's <br />question. A new PMT for both the East Pit and West Pit was approved with Technical Revision <br />63 (approved on 1 June 2007). If Colowyo submits a new PMT for the East Pit "...within the <br />next year...", the majority of the East Pit will be'backfilled and regraded. The Division does not <br />4
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