Laserfiche WebLink
COAL <br />s <br />COMPANY <br />AEOpLE•PRODUC,riOls £13 <br />Colowyo Coal Company is seeking only to revert back part of the way to <br />the Curve Numbers that were adopted previously based on the NEH <br />recommendations and the Striffler and Rhodes data. By contrast, the <br />increase in Curve Numbers on reclaimed lands in TR -73 seems to have <br />been arbitrary and without technical justification. CCC believes the 76 <br />data points of actual infiltration tests on reclaimed lands, all showing <br />HSG B or higher, and the fact that all nearby mines in the region use <br />Curve Numbers in the 60s which can only be achieved by assuming a soil <br />with infiltration rates as observed in the Striffler and Rhodes study (i.e., <br />HSG B), is sufficient data to justify a revision. If CDRMS cannot reach <br />this conclusion, CCC at least requests the agency delay its action on this <br />TR until additional field tests can be performed. <br />DRMS July 2, 2012 Follow up Comment to Comment 3 above: <br />Based on the response letter, it appears that CCC is willing to <br />consider the idea of performing on -site infiltration tests. The Division <br />believes that this is the best course of action to determine soil types of <br />disturbed areas. It would be best to perform these in any areas where <br />revised modeling is planned. To help facilitate the process by insuring <br />that CCC and the Division are in agreement on methodology, the <br />Division would like to review the plan for any infiltration tests prior to <br />implementation. <br />Colowyo's Second Round Response to Original and Follow up Comment 3: <br />It is Colowyo's position that removing the Prospect Drainage from this <br />discussion and focusing on recent and past water quality compliance <br />performance of the remaining reclamation areas and discharge structures <br />should allow the Division to reconsider and approve the June 25, 2012 <br />submittal as written. <br />Given the arguments presented in Colowyo's response to the previous two <br />Division comments, Colowyo does not feel it is reasonable or justifiable to <br />implement what is an extremely expensive and time consuming project that <br />when completed is not guaranteed to provide relief from this issue. <br />4) DRMS Original Comment 4: <br />A Western Fuels - Colorado, LLC mining property <br />