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NUCLA PR NO. 2 <br /> pipe with the orifice opening cut on the side of the riser pipe to be an <br /> effective and efficient design of a combination principal and emergency <br /> spillway, while at the same time providing adequate detention time and <br /> an automatic dewdtering device. Peabody has committed to providing <br /> trash racks over the principal and emergency spillway openings; <br /> therefore, clogging of the pipe should not be a problem. <br /> In conclusion, Peabody does not feel OSM's requirement is contained in <br /> CMLRD's Rules and Regulation; nor does Peabody feel OSM's requirement is <br /> required based on the design objectives of the regulations. Therefore, <br /> Peabody requests approval of Pond 007's principal and emergency spillway <br /> ds designed. <br /> Tab 14 - Blasting <br /> Comments : <br /> 1. Pages 14-5 and 14-6 indicate that 7 dwellings are located within <br /> 1 ,000 feet of the proposed blasting area and that 2,300 feet of <br /> sewage line is located within 500 feet of the proposed blasting <br /> area. Because of the close proximity of these structures, the <br /> requirements of Rule 4.08.4(7) are applicable. Based upon the <br /> information submitted to the Division at this time, the Division <br /> will not approve blasting within 1,000 feet of any of these <br /> dwellings or within 500 feet of the sewage line. In order for the <br /> Division to consider lesser distances, it will be necessary for <br /> Peabody to perform a pre-blast survey of each dwelling and of the <br /> sewage line. Also, Peabody will have to perform a comprehensive <br /> determination of what blasting load levels would preclude damage to <br /> these structures. The standard equation addressed in Rule <br /> 4.08.4(10)(b)(i ) may not necessarily be acceptable due to the close <br /> proximity of these structures to the proposed blasting area. Also <br /> data from seismic recordings needs to be submitted to substantiate <br /> Peabody's position. Peabody should consider performing monitoring <br /> of blasting on portions of the permit area which do not fall within <br /> the restricted proximity. <br /> Response: <br /> As discussed with Jim Pendleton and Sue Mowry, CMLRD, Peabody is <br /> performing field tests at the Nucla Mine and will be correlating this <br /> data with expected mining conditions and proximity of adjacent <br /> structures and facilities at the Nucla East Mine area. Upon completion <br /> of these tests , response to this comment will be submitted to the <br /> Division. <br /> Tab 15 - Hydrologic Monitoring <br /> Comment: <br /> 1. Please submit lithologic logs for Wells GW-N14, GW-N15, GW-N18, <br /> GW-N20, GW-N21, and GW-N17P. <br /> 23 <br />