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2011-05-12_APPLICATION CORRESPONDENCE - C2010088
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2011-05-12_APPLICATION CORRESPONDENCE - C2010088
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Last modified
8/24/2016 4:33:27 PM
Creation date
5/13/2011 7:57:24 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010088
IBM Index Class Name
Application Correspondence
Doc Date
5/12/2011
Doc Name
2nd Surace Water Adequacy Review
From
Joe Dudash
To
Mike Boulay
Email Name
MPB
JJD
Media Type
D
Archive
No
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Page 5 of 6 <br />58. On permit text pages 2.05-18 and 2.05-19 in Section 2.05.3(4)(a)(ii)(C), please describe where <br />the excess sediment from the pond cleanings will be disposed. <br />The Division has no further concerns. As described in the April 11, 2011 submittal on revised <br />permit text page 2.05-28, any coal fines from sediment pond and ditch cleaning will be <br />disposed of at the McClane Mine. As is mentioned in the April 11, 2011 cover letter, the <br />McClane Mine permit will need to be revised to include this operation. <br />59. As stated on permit text page 2.05-20 in Section 2.05.3(4)(d), the Division has to make a <br />finding that runoff from disturbances within 100 feet of Reed Wash will comply with Rule <br />4.05.18. If sediment ponds 3 and 4 are eliminated and best management practices are <br />employed through a revision of the sediment control system for the rail loop, please revise <br />permit text page 2.05-20 to show how the requirements of Rule 4.05.18 will be met. If silt fence <br />is used, the Division requests that Sedcad designs for silt fence be provided for those stream <br />buffer zone areas in order to demonstrate compliance with the stream buffer zone rule. The <br />Division will make the findings once the sediment control system designs have become final. <br />The Division has no further concerns. Although the silt fence designs are not needed from the <br />standpoint of a haul road not within the disturbed area, the silt fence designs were provided to <br />demonstrate that runoff from the disturbed areas will be in compliance with Rule 4.05.18. The <br />Division will make its findings concerning Rule 4.05.18 once the hydrology review is finished. <br />60. If CAM elects to revise the sediment control system and eliminate most of the sediment ponds <br />for the railroad loop and, instead, uses best management practices, please revise the protection <br />of hydrological balance discussion in Section 2.05.6(3), the water depletion estimate in Section <br />2.04.11(4) and any other relevant permit section. <br />The Division has no further concerns. Sections 2.05.6(3) and 2.04.11(4) were revised in the <br />submittal dated April 11, 2011. <br />94. In the Probable Hydrologic Consequences Section 2.05.6(3)(b)(iii) on permit text pages 2.05- <br />49 and 2.05-50, it is stated that surface water is unlikely to recharge the alluvial ground water <br />system and some general assumptions are provided. Please add specific information to the <br />discussion that supports this assertion. <br />The Division has no further concerns. BRL added information concerning evaporation, <br />infiltration and pond operations to revised permit text pages 2.05-52 and 53 in the April 11, <br />2011 submittal. <br />95. In Section 2.05.6(3) (b) (iv) on permit text page 2.05-58, it is stated that water monitoring <br />records will be maintained on site and submitted to the Division annually. Please add that the <br />discharge monitoring reports for the NPDES permit will be submitted to the Division on a <br />quarterly basis, as required in Rule 4.13(2)(a)(iii).
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