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specific BMP's and general protective measures previously detailed for the 18LT Pipeline, and outlined for pipeline <br />disturbances will be utilized to control surface runoff and sediment. Surface disturbance areas associated with pipeline <br />• construction will be reclaimed concurrently with ongoing pipeline construction, and regraded surface areas will be left <br />in a roughened condition, to control runoff and erosion, until they can be seeded. As a very limited disturbance area (a <br />maximum of approximately 300 ft x 40 ft, or 0.28 acres) the active pipeline construction areas meet the applicable <br />criteria for a Small Area Exemption, and construction of full -scale drainage and sediment control structures is neither <br />needed nor justified. <br />19RT Mine Dewatering Borehole and Pipeline (TR10 -73) <br />During construction, and for the minor surface structures that will remain during mining, drainage and sediment control <br />for the 19RT Mine Dewatering Borehole and Pipeline will be provided by Alternative Sediment Controls (ASC's) <br />consisting of combined Best Management Practice (BMP) measures. BMP's for the construction activities include: <br />• Minimizing the area of surface disturbance <br />• Scheduling of construction activities during the dry summer period <br />• Placement of staked straw wattles downgradient of all surface disturbance areas to intercept any surface runoff <br />and trap associated suspended solids <br />• Soil replacement and stabilization with either the standard rangeland or pastureland seed mixtures (as <br />appropriate) in a timely manner following completion of construction activities <br />Construction - related surface disturbance will be limited to soil removal and windrowing from the pipeline trench <br />alignments and stockpiling for the borehole pad area, excavation of the trenches and temporary stockpiling of excavated <br />material adjacent to the trench, minor cut/fill grading to establish the borehole drill -pad, and excavation of temporary <br />cuttings pits. <br />• Where pipeline disturbance traverses steep slopes, additional staked straw wattles will be placed on- contour to limit <br />overland flow following revegetation seeding. Drainage and sediment control for the associated minor surface <br />structures (borehole surface casing and any manhole(s)) will also utilize BMP's including the vegetative filter provided <br />by temporary vegetative stabilization, and berms and/or wattles, as appropriate. The pad for the 19RT Mine <br />Dewatering Borehole installation has been designated as a Small Area Exemption (SAE), and the limited drainage from <br />this small area (0.35 acres) will be controlled by staked straw wattles, and reclamation/stabilization of the pad area <br />following well installation. Temporary drainage and sediment control measures will remain in -place until vegetation is <br />sufficiently established to effectively control runoff, erosion, and sediment loss. <br />As relatively small isolated surface disturbances, the additional disturbance required to construct ditches and <br />sedimentation ponds to intercept, route, and treat runoff from the dewatering borehole pad, is not warranted. Similarly, <br />for the associated temporary linear pipeline disturbances, construction of ditches and ponds to control runoff is <br />impractical. Runoff from these small disturbance areas will move downslope toward Fish Creek through areas of <br />extensive natural vegetation, which will supplement the ASC's, effectively serving as a vegetative filter. The proposed <br />BMP's have proven effective in controlling runoff and sedimentation from similar disturbances. Special design, <br />construction, and operational measures have been incorporated in the design plans to assure that there will be no <br />discharge or mixing of mine water with surface drainage. <br />Following installation of appropriate ASC's for each portion of the project disturbance, available soil materials will be <br />bladed from any new disturbance areas and temporarily windrowed or stockpiled on the upgradient edge of these <br />disturbance areas. For pipeline trench areas, consideration of soil horizon segregation must be balanced with the <br />objective of limiting overall surface disturbance. In the interest of minimizing overall surface disturbance, TCC <br />proposes to not segregate and separately stockpile individual soil horizons for the pipeline trench disturbance, and <br />submits that this approach will not significantly alter soil suitability characteristics, since the differences between the <br />• soil horizons is not significant over the areas to be affected by trenching. For the borehole drill -pad, individual soil <br />horizons will be segregated, if present. <br />Soil materials will be replaced following completion of pipeline installation. Reseeding of the disturbed areas will <br />be completed during the first appropriate planting period following soil material replacement. When no longer <br />TRIO-73 2.05 -84.7 05/21/10 <br />