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Summary of Adequacy Review for TR-123 <br />Mine: West Elk Date review completed: 12/23/10 <br />Permit No.: C-80-007 DRMS reviewer: Tom Kaldenbach <br /> Require- <br /> ments <br />Requirements complied Comment <br /> with ? (yes <br /> / not <br /> A PR is not necessary based on the proposed work. The polygons approved in <br /> PR-14 for the following MDWs are proposed in TR-123 to be moved <br />2.08.4 Revision type approximately 200 feet (PR-14 cross-cut nos. are in parentheses): E3-44(45) <br />(PR, TR, or MR) and 47 (48.5), E3-14(15). All other MDW locations in the 2011 drilling plan <br /> are the same as approved in PR-14. TR-123 proposes no new MDWs. TR- <br /> 123 proposes a new road segment connecting E3-17.5(18) to E3-25(26.5). <br />2.03.6(1) Right of USFS clearance was provided for most of the work in PR-14 (MDWs) and <br />entry yes PR-10 and PR-12 (coal leases). Needed USFS clearance new road <br />' <br /> alignments and shifted polygons provided in Dan Grey <br />s email of 12/23/10. <br />Cultural resources <br />See <br />(2.04.4) and Awaiting SHPO verification that previous clearance in PR-14 suffices. <br />2.07.6(2)(e) i) comment <br />Fish/wildlife <br />information (2.04.10, <br />yes <br />Proposed work is covered by PR-14 clearance. <br />2.04.11, 2.05.6(2), <br />2.07.6 and 4.18) <br />Maps and plans The submittal includes a PE-certified map and PR-14's previously <br />(2.10) yes a roved generic mud it design applies. <br />Light-use roads <br />(4.03. Light-use <br />yes <br />New road segment and alignments do not exceed grade requirements. <br />Topsoil (4.06) and <br />topsoil markers Topsoil will be stockpiled and marked, as previously described in PR-14. <br />(4.02.7) <br /> Runoff can be expected to be alkaline with quality similar to pre- <br />Water quality disturbance conditions. The proposed work will not generate significant <br />protection (4.05.2) yes quantities of leachate-forming substances. The runoff from disturbed areas <br /> will be too alkaline to form leachates or to mobilize metals. <br /> The mudpits will not be part of the sediment control system for the drill <br /> pads. The mudpits will be impoundments (1.04(64)) that will not have <br /> spillways (4.05.9(2)(e), will be located where failure would not be expected <br />Impoundments to cause loss of life or serious property damage (4.05.9(2)(e), and a safety <br />(4.05.9) yes factor demonstration was previously submitted in TR-101. The PE-certified <br /> mudpit design previously submitted in PR-14 shows the mudpit is sized to <br /> hold all of the cuttings from the borehole and the surface runoff, with 1 ft. of <br /> freeboard, from a 25-yr., 24-hr. storm (4.05.9(2)(c)). <br /> The drillpads will be SAEs utilizing alternative sediment control measures <br /> such as slash, silt fence, or straw wattles. SEDCAD runs previously <br />Sediment control submitted in PR-14 for a typical drill pad use reasonable curve numbers and <br />(4.05.5) yes other variables. The SEDCAD runs indicate the proposed alernative <br /> sediment control methods will effectively control sedimentation. The mud <br /> its will not be art of the sediment control system for the drill ad.