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Colowyo, C1981-019, PR3 adequacy No. 2 17 April 22, 2011 <br />Collom Gulch, north of the permit area there is some Cropland. In the Vegetation Map 4C <br />(Sheet 1 of 11) it shows that the same area is Bottomland. Looking at the Bottomland <br />Vegetation Information outlined in Section 2.04.10, page 61 of the permit application, <br />describes Bottomland vegetation to be comprised of sagebrush, mountain shrub and grasslands. <br />Does the Bottomland have agricultural significance? <br />CCC's response is adequate. <br />6. The Division requests that an alluvial monitoring well be installed downstream in Collom <br />Gulch, north of the permit area and Highway 32,. This area is a documented alluvial valley <br />floor according to the OSM 1985 Reconnaissance Map, and because of its close proximity to <br />the permit area it would be beneficial to have baseline data and long term monitoring <br />throughout the life of mine. According to Rule 4.24.3(3), surface coal mining and reclamation <br />operations shall not cause material damage to the quality or quantity of water in surface or <br />underground water systems that supply alluvial valley floors. According to Rule 4.24.4(1), an <br />environmental monitoring system is required on all alluvial valley floors through Phase III <br />bond release. <br />CCC's response is adequate. <br />7. At this point, the Division does not have adequate information to make a determination on the <br />presence or absence of AVF's. Once the questions above are adequately addressed, we will <br />make a determination as required by Rule 2.06.8(3)(c). Additional information may be needed <br />if we make a positive determination that an AVF does exist downstream in Collom Gulch. <br />The Division did not need a response from CCC. DRMS will make this determination. <br />Rule 4.05.2 Water Ouatity Standards <br />1. The Division reviewed the demonstration for ring ditches around topsoil piles in Exhibit 7, <br />Item 23. The design includes the use of small, incised impoundments in combination with the <br />ring ditches. Exhibit 7-23D Figure 1 shows the incised impoundments and labels them with the <br />annotation "small impoundment incised per design in XXXXX." Please provide the design for <br />these small impoundments. <br />The response is inadequate as additional information is needed. How is runoff from above the <br />topsoil stockpiles prevented from entering the ring ditch? Does CCC plan to use clean water <br />diversions above topsoil stockpiles? <br />2. For any small disturbed areas as defined by Rule 1.04 (commonly referred to as SAE'S) that <br />will not report to sediment ponds, please provide a demonstration that the applicable effluent <br />limits can be met using alternative sediment control methods. This can include topsoil piles <br />and areas where it is impractical to divert runoff using diversion ditches. Numerous, small <br />disturbed areas currently appear outside of sediment containment on Map 41 B. If these areas <br />are planned to be outside of containment ditches, they will need to be SAE's.