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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
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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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affected by mining- related surface disturbances. Please describe on page 7 of Section <br />2.05.6(3) the measures that will be used to ensure compliance with Rule 4.05.18. Before the <br />Division can make a proposed decision on the new permit application, the Division will <br />need this information when it makes its findings of compliance with Rule 4.05.18. <br />Response - The stream buffer zone along the Meehan Draw will be affected by mining. <br />The text has been revised to account for this. Activities along the stream buffer zones will <br />be performed as per the ACOE 404 permit. <br />3. In the second full paragraph on page 8 of Section 2.05.6(3), it is stated that calculations were <br />made that determined that there would not be significant impact to receiving stream water <br />quality and water rights due to mine discharges. Please provide the calculations or reference <br />on page 8 where in the permit application these calculations can be found. <br />Response - See Table 2.05.6(3)-2 on page 29. The text has been revised as suggested. A <br />statement to this effect has been added in the text. <br />4. In the second full paragraph on page 8 of Section 2.05.6(3), it is stated that present or <br />potential uses of the water were not considered in the determination of no significant injury <br />to receiving stream water quality and water rights due to mine discharges. Please explain <br />why present or potential uses were not considered. <br />Response - Present uses of surface water in Tuttle and Coal Creek do not exist primarily <br />because there is no practical way (gravity flow) to divert stream bottom irrigation run off <br />water to upland tillable lands. There are no present or potential uses because of the <br />existing water quality. A statement to this effect has been added in the revised Section <br />2.05.6(3). <br />5. In the second to last paragraph on page 8 of Section 2.05.6(3), it is stated that WFC will file <br />for an augmentation plan with the Water Court. Please provide a copy of the augmentation <br />plan to the Division when it is approved and reference the location of the plan on page 8. <br />Response - The Water Court is currently considering WFC's Water Augmentation Plan. <br />Once approved, a copy of the approved plan will be submitted to DRMS to be inserted in <br />Appendix 2.05.6(3)-lc. The text has been corrected as suggested. <br />6. In the top paragraph on page 9 of Section 2.05.6(3), it is stated that WFC plans to operate a <br />Substitute Water Supply Plan. Please provide a copy of the plan to the Division when it is <br />obtained and reference the location of the plan on page 9. <br />Response - Please see the response to 5. above. <br />7. On page 6 of Section 2.05.6(3), Protection of the Hydrologic Balance, it is stated that <br />excessive leakage from the sediment ponds will be avoided by compaction of the pond <br />bottoms and sides. Please explain what "excessive" is and why the ponds should not be <br />lined. This section will be revised to conform to construction practices of sediment ponds at <br />the New Horizon Mine. <br />Response -As discussed with DRMS, the referenced sentence has been deleted from the <br />text. <br />Response to First Adequacy Review Page 46
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