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2011-12-01_APPLICATION CORRESPONDENCE - C2010089 (2)
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2011-12-01_APPLICATION CORRESPONDENCE - C2010089 (2)
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Last modified
8/24/2016 4:45:31 PM
Creation date
12/2/2011 8:24:26 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
Application Correspondence
Doc Date
12/1/2011
Doc Name
Preliminary Adequacy Review No. 2
From
Western Fuels Association
To
DRMS
Email Name
MLT
SB1
Media Type
D
Archive
No
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WFC believes that these data confirm the fact that there is no justifiable reason to <br />require that topsoil and subsoil be segregated at the proposed NHNMine. <br />17. Topsoil storage is described beginning on page 15 of Section 2.05.4(2)(d) of the application. <br />Please expand the narrative to describe the volume and type (assuming that two -lift salvage <br />and replacement of the Progresso soils is implemented) of any stockpiles that will be <br />constructed, and give the side slope configuration (H:V) proposed to achieve stability. <br />Please also provide a reference to the map on which the stockpile locations are shown. <br />Response — This information is now included in page 12 of Section 2.05.4(2)(d) including <br />a reference to Map 2.05.3(3) -3 for stockpile location <br />2.05.4(2)(e) — Revegetation plan <br />5. A distinction was made in Section 2.04.10, page 31 -33, between Irrigated Pasture (IP) and <br />Intensively Managed Irrigated Pasture (IMIP). It is explained that a reference area approach <br />will be used for the IP areas and a "Historic Record" method will be used for IMIP areas. In <br />Section 2.05.4(2)(e) the distinction between the two different land management practices is <br />not as clear. Revegetation methods, Success Criteria and Success Demonstrations are <br />explained for the IP areas, but are not explained for the IMIP areas. Please include in the <br />PAP an explanation of the Revegetation methods, Seeding Procedures, Bond Liability <br />Period Management, Soil Analysis, Success Criteria, Success Demonstrations and how the <br />"Historical Record" will be utilized for the IMIP areas. <br />Response — The requested text regarding the use of historic information for IMIP areas is <br />now included in page 11 of revised Section 2.04.10. Other issues are already addressed in <br />Section 2.05.4(2)(d). <br />2.05.5 — Postmining Land Uses <br />1. DRMS: Map 2.05.4 — Post mining Land Use, does not have all the symbols used on the map <br />represented in the legend. Please include in the legend a description of: the sage green in the <br />southern end of the property, the nine red circles with three red lines labeled DH1 -9, the green <br />checkered area on the Garvey property, and the white areas. Also, in the lower right corner, <br />Kent Crofts signed the map as being prepared on 19 Nov, 2009, while in the lower left corner, <br />it says the map was created on 6/14/10. Please clarify and use the correct date on the map. <br />Response — DRMS has incorrectly referred the map as Map 2.05.4. It should have been <br />Map 2.05.5 -1. The red circles found on this map, were generated in error. Map 2.05.5 -1 <br />Post Mining Land Use has been revised to address these concerns. <br />2. DRMS: In section 2.05.5, page 4, last paragraph of the permit application, WFC is proposing <br />to change "Irrigated Pasture to Dryland Pasture." This may be a typo that needs to be <br />corrected. If it is not a typo, then WFC needs to discuss why it is proposing to lower the <br />production value of the irrigated pasture. Rule 4.16 clearly states that "All areas affected by <br />surface coal mining operation shall be restored in a timely manner 1) to conditions that are <br />capable of supporting the uses which they were capable of supporting before any mining..." <br />Also, the contract with the land owner, Stan Garvey, does not have provisions for converting <br />irrigated pasture to dryland pasture (Appendix 2.05.5 -1 in PAP). Please explain why WFC is <br />Page 29 <br />
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