2014-08-06_REVISION - C1981044 ‎(2)‎

• 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

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.
H. 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
are included with these responses. It is MCM's understanding that the Division will utilize this
updated information to review and revise the reclamation cost estimate, and will provide the
revised estimate for MCM's review. Once the updated reclamation cost estimate is finalized, a
copy will be inserted in Exhibit 25. If the Division incorporates the relevant historical
information from the current cost estimate in this update, it will replace the current cost estimate
in Exhibit 25, otherwise, the current cost estimate will be retained as relevant historic
background, and the updated cost estimate will be added to Exhibit 25.
b) DRMS Response: The Division has reviewed the updated Table 56, Map 25 and the "Mine
Facilities" discussion in Section 2.05.3 of the PAP and identified several issues that will need to
be addressed. Please address the items below: