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Colowyo, C1981-019, PR3 adequacy No. 2 10 April 22, 2011 <br />Collom Expansion Area and do not effect or change the existing reclamation procedures, <br />standards or timing of the Colowyo Mine. <br />CCC has clarified that the reclamation standards contained in Volume 15 pertain solely to the <br />Colloin expansion and do not change the previously approved standards for the Original permit <br />area, East Pit, Section 16, West Pit and South Taylor mining areas (Rule 2, pagel08). This <br />response is acceptable to the Division. This item has been resolved. <br />2. Page 106, first paragraph - The text explains that the final grading of the mine will result in <br />approximately 20%o to 40% of the terrain with a slope less than 10%. In contrast, the graph on <br />Map 19D indicates that the percent of final grading with a slope less than 10% is approximately <br />37%. It is understandable that a certain amount of error exists in the mapping due to the 100 <br />foot by 100 foot grids used in the percent slope calculations, but it would be logical that the <br />error be more evenly distributed around the mean 37%. The Division suggests that a target of <br />37% of the terrain have less than a 10% slope with amargin of error +/- 2%0. If it is determined <br />during the reclamation process that a 1Q% slope on 37% of the terrain is not possible, the <br />Division and Colowyo will then determine an appropriate percentage of terrain with a slope <br />less than 10% through a technical revision. <br />Page 108, third paragraph - The Division is not proposing an "additional" target to the PMT as <br />suggested in Colowyo's response. The graph on Map 19D documents the PMT with a slope <br />less than 10% will be 37%. The permit text needs to accurately reflect this standard set by <br />Colowyo. The commitment to "attempt inearnest on approximately 20%0 (or more) of the <br />reclaimed landscape, with the goal of achieving success on at least one-half of this acreage," is <br />inadequate for wildlife habitat. In a letter dated Feb 22, 2011, the US Fish and Wildlife Service <br />expressed concern that "approximately 20 percent of the expansion area to sagebrush would <br />fall short of the site's original condition and potential," which could impact local sage-grouse <br />populations. Please amend the text to accurately reflect the 37% standard proposed by <br />Colowyo with a smaller margin of error (ex. f 2-3%). <br />3. Page 108, third paragraph - When situations arise that require Colowyo to deviate from the <br />approved reclamation plan, the Division needs to be contacted before any action is taken. The <br />Division feels that an adequate amount of flexibility is built into the Division's permitting and <br />inspection system that allows for "on-the-ground" reality. The Division makes monthly mine <br />inspections with mine personnel to discuss various issues of which include reclamation <br />progress. During these routine inspections, mine personnel have the opportunity to discuss <br />reclamation operations and any foreseeable shortcomings in the permitted/approved design. If <br />the mine reclamation specialist and the Division feel that a revision is warranted because of an <br />unforeseen/unplanned "on-the-ground" reality, then a revision to the permit will be submitted <br />to the Division at that time. The Division requests therefore, that this paragraph be removed <br />from the permit. <br />Page 118, last paragraph - The additional language added to this paragraph does not add <br />clarification as to when deviation from the permit is acceptable. The Division reaffirms its <br />position that when a situation arises that requires Colowyo to deviate from the original permit, <br />