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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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Last modified
8/24/2016 4:34:06 PM
Creation date
6/3/2011 8:50:28 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
APPLICATION CORRESPONDENCE
Doc Date
6/2/2011
Doc Name
Response to Preliminary Adequacy Review
From
Western Fuels Association
To
DRMS
Email Name
MLT
SB1
Media Type
D
Archive
No
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Response - Section 34-33-I20(2)(e) of the Act states that the operator is required to <br />"remove the topsoil from the land in a separate layer ... " With respect to the segregation <br />of topsoil and subsoil materials the regulations state at Rule 4.06.1(1) that topsoil and <br />subsoils "shall be separately removed and segregated from the other materials." This <br />regulation is consistent with the Act that requires that topsoil be removed in a "separate <br />layer" not that topsoil and subsoil be removed as "separate layers. " Rule 4.06.4(3) <br />requires that topsoil and subsoil "shall be segregated and replaced as subsoil, only if the <br />Division determines that such material is necessary to ensure soil productivity consistent <br />with the approved postmining land use." The only place in the regulations where the <br />Division has determined that it is necessary to segregate topsoil and subsoil materials is <br />found in Rule 4.25.2 relative to Prime Farmland, where it states that the "A horizon" and <br />`B horizon" shall be removed separately. WFC's current NH2 permit follows these <br />identical practices, the mixing of topsoil and subsoil on all affected and reclaimed areas, <br />except for those areas designated as Prime Farmland Our experience as well as <br />consultation with numerous other coal operators in the state reveals that apparently the <br />only mine that appears to be segregating topsoil and subsoil is the NH2 Mine as it applies <br />to Prime Farmland. If the Division is now determining that such as practice is <br />"necessary" as required by their regulation, then we would request that WFC be provided <br />the documentation and published articles the Division is using to justify this position. <br />2.05.4Q) Le) - Revegetation plan <br />1. 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 />Response - Our examination of Seed Mixture No. 8 shown on PAP Section 2.05.4(2) (e) <br />page 12 with thatfound on page 24 reveals that they are identical, Therefore the <br />duplicate seed mixture No. 8 shown found on page 24 will be deleted from the permit text. <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 herbaceous <br />and woody vegetation..." Please commit to one method or the other. <br />Response - Canopy cover will be the method used to determine the successfulness of plant <br />cover on the dryland pasture reclaimed areas at the NHN Mine and the corresponding <br />text on page 26 of Section 2.05.4(2)(e) has been modified accordingly. <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 />Response to First Adequacy Review Page 40
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