2014-07-08_REVISION - C1981044 - Laserfiche WebLink

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i. Under the Yampa River section, please revise the language to indicate that development mains and sub -mains have been driven under the Yampa River AVE The proposed language of this section indicates these operations occurred under the Williams Fork River AVE ii. Under the Williams Fork River section, please indicate what mining and development work has been done under this AVF and how it has been protected from subsidence. Response: Page 2.05 -53 has been revised to clarify historic mining under the Williams Fork River and associated AVF and address subsidence considerations, and the revised page is included with these responses. 29. The discussion of mining under the alluvial valley floors within the Williams Fork Mines' permit area, beginning on permit page 4.01 -13, only includes information for the first permit term. The Williams Fork Mines is currently in its fifth permit term. Please update the discussion of mining activities under the Yampa River (Big Bottom) and Williams Fork River Alluvial Valley Floors for all permit terms up to and including the current permit term. If MCMprovides a Permit Revision with anew mine plan, this section of the permit will need to be updated with the future (planned) mining information as well. a. MCM Response: The specific Permit text discussion for alluvial valley floors has been reviewed and updated, as appropriate, to reflect current status and conditions. Copies of the revised Permit discussion accompany these responses for replacement in the PAP. b. DRMS Response: i. Revised section 4.24 on page 4.01 -13 discusses the operations on the Yampa River Alluvial Valley Floor area. The revised wording indicates that no underground mining has been done or is planned in this area. This statement is inaccurate and in conflict with permit section 2.06.8 (page 2.06 -3). It appears partial extraction has occurred under the Yampa River AVF of the "F" seam. Also potential development is planned in this area as depicted on Map 23 and 24 of both the "F" and "E" seam for the life of the mine. Please revise this information. ii. Permit Section 2.06.8 needs to be updated to account for subsequent mining and development since the first permit term. Response: Permit sections 2.06.8 and 4.24 have been reviewed and revised to clarify historic mining under the Yampa River and associated AVF, address subsidence considerations, and update the information to reflect mine development to date. The revised pages are included with these responses. Reclamation Cost Estimate; Response to MCM Bonding Review Comments Memo Included with TR36 The Division has conducted a review of the reclamation cost estimate as requested. The current liability set for the mine is $3,590,971.00. This was the estimated cost based on the Midterm Review No. 6 (MT6) conducted by the Division on June 28, 2011. MCM bond review comment memorandum submitted with TR36 indicates the most recent liability amount is $3,464,926.00 which is incorrect. It appears this amount was the revised liability estimate set during the review of Technical Revision No. 34 (TR34) approved on November 16, 2007. However, the liability amount from TR34 has been carried over to the proposed decision form for MR50 approved on February 27, 2013. This is likely due to a coding error in the Division permit tracking system. Given that the actual liability amount is $3,590,971.00 from the most recent cost estimate conducted for MT6, the increase in costs for RN6 are not as significant as portrayed in the bond review comment memo MCM submitted with TR36. 1) MCM Concern Task 001: Demolish and Remove all Structures - +$180K (25%) a) DRMS Response: The MT6 total cost for Task 001 was estimated to be $866,069.52. The RN6 estimate for Task 001 was $887,305.42 which is $21,235.90 more than the MT6 cost. This is about a 2.5% increase from the MT6 estimate conducted in 2011. However, it appears the hours associated with this task is