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2014-07-08_REVISION - C1981044
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2014-07-08_REVISION - C1981044
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Entry Properties
Last modified
8/24/2016 5:45:33 PM
Creation date
7/10/2014 10:40:05 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981044
IBM Index Class Name
Revision
Doc Date
7/8/2014
Doc Name
Technical Adequacy Response Package and Request for Extension (emailed)
From
Twentymile Coal, LLC
To
DRMS
Type & Sequence
TR36
Email Name
JLE
Media Type
D
Archive
No
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Response: MCM documents weed control activities in both the text and on a map in the Annual Reclamation <br />Report. Generally, the areas delineated may include multiple weed species, therefore specific locations are not <br />delineated for individual species. MCM typically sprays in the spring for whitetop, houndstongue, knapweed, and <br />toadflax (if present), and in the fall for thistle and any of the other species which remain after the spring weed <br />control efforts. The exception to this approach is tamarisk, which only occurs in certain areas and requires a <br />separate, focused control effort. When tamarisk control activities occur, they are delineated separately in the ARR. <br />22. Permit page 2.05 -32c states that MCM will perform revegetation monitoring in the third year following <br />seeding. Several areas were reclaimed during the 2008 field season, making 2011 the third growing season. <br />MCM is reminded that revegetation monitoring is required for these reclaimed areas this year. Please include <br />the vegetation monitoring report with the 2011 Annual Reclamation Report. <br />a. MCM Response: MCM is completing the required revegetation success monitoring in <br />conjunction with similar work for the nearby Seneca II and Yeast Mines. The resulting monitoring <br />information will be included with the 2011 Annual Reclamation Report. <br />b. DRMS Response: It does not appear MCM submitted the vegetation monitoring data with the <br />2011 Annual Reclamation Report. However monitoring was conducted in 2011 on 11.5 acres <br />reclaimed in 2008 and submitted with the SL -3 bond release application. According to the 2013 <br />Annual Reclamation Report, final reclamation was completed on 17.1 acres encompassing the No. <br />9 Portal Area and adjacent Refuse Disposal Area in May of 2009. Given the commitment <br />discussed above, revegetation monitoring should have been conducted on these areas in 2012. <br />Please indicate if the 2012 monitoring was conducted? <br />Response: Due to droughty conditions, and concerns that any monitoring would not be representative of normal <br />conditions, MCM did not conduct revegetation success monitoring in 2012. MCM plans to complete monitoring in <br />2014. <br />23. Permit page 2.05 -33 discusses the reclamation and revegetation plan that will be used on the "No. 9 Portal <br />Area /Refuse Pile ". The No. 9 Mine refuse pile was reclaimed in 2009. Please update the text on permit page <br />2.05 -33 to include a discussion of how the No. 9 Mine refuse pile was reclaimed. <br />a. MCM Response: The referenced Permit text discussion has been reviewed and updated, as <br />appropriate, to reflect recent site reclamation activities. Copies of the revised Permit discussion <br />accompany these responses for replacement in the PAP. <br />b. DRMS Response: Please revise the first paragraph under the "No. 9 Portal Area /Refuse Pile" <br />section to clearly indicate the pasture reference area to be used for this parcel is depicted on Map <br />20. <br />Response: Page 2.05 -33 has been revised to reference Map 20, and the revised page is included with these <br />responses. <br />24. The information contained in this section is out of date with regards to the permit term information and <br />anticipated mining dates. Several of the specific pages where the dates are incorrect are 2.05 -48.1, 50, 51, 52, <br />53, 63 and 65. Although subsidence monitoring has been discontinued at the Williams Fork Mines (with TR -12 <br />and TR -30), this information still needs to be updated. Please update the permit term information and <br />anticipated mining dates that are listed in the text in the subsidence control plan, which begins on permit <br />page 2.05 -48 <br />a. MCM Response: The specific Permit text discussion for the Subsidence Control Plan has been <br />reviewed and updated, as appropriate, to reflect current status and conditions. Copies of the <br />revised Permit discussion accompany these responses for replacement in the PAP. <br />b. DRMS Response: Revised Page 2.05 -53; under the "Renewable Resources Lands" section <br />updates the discussion of subsidence for the Yampa River and the Williams Fork River. Please <br />address the following issues: <br />
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