2014-10-01_REVISION - C1981044

• Permit No: C1981044
• IBM Index Class Name: Revision
• Doc Date: 10/1/2014
• Doc Name: Adequacy Review Response IV
• From: Moffat County Mining, LLC
• To: DRMS
• Type & Sequence: TR36
• Email Name: JLE
• Email Name: DIH
• Media Type: D
• Archive: No

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.
MCM Response #2: 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.
d. DRMS Response #2: This item is considered resolved.
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 TR36IRN6. 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