2014-02-21_REVISION - C1981013

• Permit No: C1981013
• IBM Index Class Name: Revision
• Doc Date: 2/21/2014
• Doc Name: Adequacy Letter
• From: New Elk Coal Company, LLC
• To: DRMS
• Type & Sequence: RN6
• Email Name: LDS
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
February 20, 2014
Louis Head
New Elk Coal Company, LLC
122 West First Street
Trinidad, CO 80182
Re: Golden Eagle Mine (Permit No. C- 1981 -013)
Permit Renewal No. 6, (RN -6)
Initial Adequacy Review
Dear Mr. Head:
COLORADO
D I V I S 16 N 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 Permit Renewal 6 (RN6) for the Golden Eagle mine by New Elk Coal
Company (NECC).
Based on the initial adequacy review, and on a review of the permit application packet (PAP), the
Division has questions and comments as listed below.
1. Rule 2.03.4 — Identification of Interests
This section should be updated to include current addresses as well as an accurate and complete
list of officers and directors of both NECC and of Cline Mining
2. Rule 2.03.10 -Identification of Other Licenses and Permits
Table 3 should be updated to show where permits have been terminated, as appropriate
3. Rule 3.02.2 - Determination of Bond Amount
The Division is in the process of re- calculating the Reclamation Cost Estimate
Rule 4.15.11 — Revegetation Sampling Methods and Statistical Demonstrations for
Revegetation Success
As has been previously discussed, reclamation success sample methodology for vegetative
cover was approved when the permit consisted of a much larger area prior to SL6 and
subsequent permit area reduction. The vegetative cover sampling methods were approved to
collect randomly distributed 25m cover transects.
Following the Division's approval of SL6 (8/26/2008), the remaining area of reclamation
liability consists of 1.2 acres of the reclaimed NW ventilation fan site, reclaimed pad and
associated reclaimed access road. The Division is concerned about the validity of applying the
currently approved sampling methods to the reduced 1.2 acre site.
Given the likelihood of a final bond release application during the next permit term, NECC is
strongly encouraged to revise this section of the permit in good time so that the sampling
methodology can be determined before any bond release application is submitted.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines