2013-11-27_REVISION - C1981012

• Permit No: C1981012
• IBM Index Class Name: Revision
• Doc Date: 11/27/2013
• Doc Name: Initial Adequacy Review Letter
• From: DRMS
• To: Greg Smith
• Type & Sequence: TR68
• Email Name: SB1
• Email Name: LDS
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
November 27, 2013
Greg Smith
New Elk Coal Company, LLC
122 West First Street
Trinidad, CO 80182
Re: New Elk Mine (Permit No. C- 1981 -012)
Technical Revision No. 68, (TR -68)
Initial Adequacy Review
Dear Mr. Smith:
STATE OF COLORADO
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pineda
Director
The Colorado Division of Reclamation, Mining and Safety (Division) has completed an initial review of
the materials submitted for Technical Revision 68 (TR68) for the New Elk mine by New Elk Coal
Company (NECC). TR68 addresses issues raised during Mid -Term Review 6 (MT6) which was
completed on October 29, 2012, as well as other inconsistencies in the permit which had been noted
during site inspections over subsequent months.
Based on the initial adequacy review, the Division has questions and comments as listed below. The
numbering corresponds to the list in the original MT6 findings document. The final numbered item in
each section of the permit has been broken up into sub -items indicated by letters which describe further
questions and comments of the Division (in many, but not all, cases these have arisen as a result of the
re- formatting of the text); this inelegant solution seemed to be the least bad option of those available.
Rule 2.03 - Legal Financial Compliance and Related Information
1. Updates to Table 2 in section 2.03
The updated table breaks the contents of single cells over multiple pages. It was requested that
MS14A permit numbers for the development waste pile (DWDA 1), DWDA 2 and the temporary
development waste storage area be added. It was also requested that a column be added to the table
to show the date of issuance of each permit — although issuance dates have been included in the
Permit/License column in some cases, the information is incomplete and the layout is unclear
2. Air permits in Table 2
The response is sufficient
3. Radioactive materials license
The response is sufficient
4. Updates to ownership of surface or coal reserves (Map 1, Map 2, pages 2.03 -5 -5a)
The owners of the surface and of subsurface coal are recorded in a table, but the table is not labeled
as such. Furthermore, the table contains an empty row, which should be deleted.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines