2014-10-06_REVISION - C1996083 (3)

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Susan Burgmaier -3- October 3, 2014 Based on the following information, it appears that BRL does not have adequate storage space in its existing refuse disposal areas to handle the refuse material that will be generated by mining in the Spruce Stomp lease area: • Map 14B indicates that the Spruce Stomp lease area will extend coal production through 2019. • BRL reported 3.3 million tons of coal produced in 2013; information provided in the quarterly refuse area inspection reports indicate that 844,429 tons of refuse were placed in the existing refuse disposal areas in 2013. That suggests a ratio of roughly 255,888 tons of refuse generated per 1 million tons of coal produced. • In 2014, 1.4 million tons of coal were produced in the first half of the year, with 528,517 tons of refuse placed. That suggests a ratio of roughly 377,512 tons of refuse generated per 1 million tons of coal produced, with is a higher ratio of refuse to coal than observed in 2013. • Based on the 2014 rate of refuse generation, as much as 5 million tons of refuse (6,493,500 CY, based on a conversion factor of roughly 1.3 CV of refuse per ton of refuse) would be produced by the end of 2019. This includes the Spruce Stomp lease area, which we estimate could alone generate as much as 3 million tons (3,896,100 CY) of refuse. • The total design capacity of Gob Piles #2, #3, and #4 combined is 4,165,000 CY. Gob Pile #4 has reached capacity. A generous estimate of the remaining capacity (combined) in Gob Piles #2 and #3 would be approximately 1.5 million CY. • Subtracting 1.5 million CV of remaining capacity in Gob Piles #2 and #3 from roughly 6.5 million CY of refuse expected to be produced between now and the end of 2019 (which includes 3.8 million CY from the Spruce Stomp lease area) indicates that BRL needs to provide a plan for on -site disposal, off - site - disposal, or both of 5.0 million CV of refuse. Please therefore provide a plan for the disposal of 5 million CY of refuse. If our estimate of 5 million CY is in any way incorrect, please let us know. BRL - BRL is in the process of developing plans for addition refuse storage. It cannot provide any specific details at this time. Please provide the Division's proposed stipulation language. The Division states it plans to place certain stipulations on its proposed decision to approve PR- 14. BRL objects to Stipulation No. 41. The Division's proposed stipulation follows: Stipulation No. 41 PRIOR TO COMMENCING ANY MINING ACTIVITIES WITHIN THE AREA OF SUBSIDENCE (INCLUDING THE ANGLE OF DRAW) UNDER THE WEST FORK OF TERROR CREEK, BRL MUST SUBMIT A COPY OF A COURT APPROVED AUGMENTATION PLAN DEMONSTRATING THAT, SHOULD MINING ACTIVITIES RESULT IN CONTAMINATION, DIMINUTION OR INTERRUPTION OF WATER IN THE WEST FORK OF TERROR CREEK, BRL HAS OBTAINED SUFFICIENT WATER RIGHTS AND AN APPROVED WATER REPLACEMENT PLAN TO RESTORE, REHABILITATE, OR REPLACE THE WATER SUPPLY.