2014-08-06_REVISION - C1981044

• Permit No: C1981044
• IBM Index Class Name: Revision
• Doc Date: 8/6/2014
• Doc Name: Adequacy Review No. 2
• From: DRMS
• To: Moffat County Mining, LLC
• Type & Sequence: TR36
• Email Name: JLE
• Media Type: D
• Archive: No

Jerry Nettleton, MCM
Page 14
August 6, 2014
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 MCM provides a Permit Revision
with a new 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.
c. MCM Response #2: 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.
d. DRMS Response #2:
i. Item 29(b)(i) is resolved.
ii. Item 29(b)(ii) is resolved.
Reclamation Cost Estimate;
MCM provided updates to Table 56, Map 25 and the "Mine Facilities" discussion in Section 2.05.3 of the
PAP to provide information to update the reclamation cost estimate for TR36/RN6. Their response to the
Division's first adequacy review concerns is below.
a) MCM Response: Table 56, Map 25, and the "Mine Facilities" discussion in Section 2.05.3 of
the PAP have been reviewed, updated, and revised for consistency and to reflect the current
disposition and status of all major mine structures and facilities. Copies of these revised materials