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2010-12-23_APPLICATION CORRESPONDENCE - C2010089
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2010-12-23_APPLICATION CORRESPONDENCE - C2010089
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Last modified
8/24/2016 4:28:14 PM
Creation date
12/27/2010 1:12:18 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
Application Correspondence
Doc Date
12/23/2010
Doc Name
Preliminary Adequacy Review (Part 1)
From
DRMS
To
Western Fuels Association, Inc.
Email Name
MLT
SB1
Media Type
D
Archive
No
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C- 2010 -089 PAR Part 1 23- Dec -2010 <br />New Horizon North Mine Page 18 of 21 <br />control ditches or terracing proposed for the reclaimed slopes. Please submit post- mining <br />contours that have contours that more closely resemble the approximate original contours, <br />4.14.2(1). <br />4. Three cross sections have been provided on Map 2.05.4 -1, depicting the pre - mining ground <br />surface and the proposed post- mining surface. <br />a) Each of the sections provided runs East -West. Please add at least one cross section <br />which runs North -South across the permit area. <br />b) Please incorporate an additional line into each of the sections which depicts the <br />anticipated limits of the mining- related excavation. <br />2.05.4(2) (d) — Removal, storage and redistribution of topsoil and subsoil <br />PAP section 2.05.4(2)(d) page 13 contains the statement, "The actual amount of topsoil <br />salvage has been less than the amount estimated in the soil survey." Please explain why this <br />has been the case in the New Horizon No. 2 Mine. Is this due to poor salvage technique, <br />poor soil resource evaluation, poor topsoil storage methods, or some other explanation? The <br />Division is concerned that WFC does not explain topsoil volume shortfall. Please provide <br />an explanation of this statement and how plans to rectify this problem. <br />2. In PAP section 2.05.4(2)(d) pages 14 and 15, WFC states that they will replace topsoil on <br />the contour except on "steep" slopes. Please provide a definition of what WFC defines as <br />"steep" slopes. <br />3. Please provide an explanation of how mixing topsoil and subsoil together complies with <br />section 34- 33- 120(2)(e) of the Act. <br />2.05.4(2)(e) — Revegetation plan <br />Seed mix No. 8 shown in PAP Section 2.05.4(2)(e) page 12 is different from the seed mix <br />shown on page 24. Seed mix No. 8 shown on page 24 is acceptable to the Division. Please <br />list each seed mix in only one Table in the PAP and reference that table where the seed mix <br />is referred to in other sections. <br />2. On permit application section 2.05.4(2)(e) page 26, there is a discussion regarding sampling <br />methods to determine reclamation success in the dryland pasture. WFC makes the statement <br />that, "Vegetation cover will be measured as either canopy or basal cover of living <br />herbaceous and woody vegetation..." Please commit to one method or the other. <br />3. WFC proposes to use a dryland pasture reference area located approximately 4 miles away <br />from the mine site at the Hopkins Field Airport in Montrose County. This Dryland Pasture <br />reference area has previously been approved for reclamation success comparison for the <br />New Horizon Mine permit. In accordance with 4.15.7(3)(b)(ii), please provide <br />verification that WFC retains the right -of -entry for surface activities on the Dryland Pasture <br />reference area. Documentation similar to that found in New Horizon Mine permit, C -1981- <br />008, Attachment 2.05.4(2)(e) -4, would be suitable to document WFC's right of entry. (Rule <br />2.03.6(1)). <br />4. Rule 4.15.7(3)(b)(iii) requires that reference areas selected for reclamation success <br />comparison should approximate the vegetation characteristics which reflect reclamation plan <br />objectives. The permittee must demonstrate that the reference area selected reflects proper <br />land management and is representative of the ecological site conditions for the reclaimed <br />
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