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New Elk Coal Company <br />4e <br />October 07, 2014 <br />Division of Reclamation, Mine and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />RE: New Elk Main (Permit No. C- 1981 -012 <br />Technical Revision No. 70 (TR -70) <br />Initial Adequacy Review Response <br />Dear: Leigh Simmons <br />DRMS — Please update table 19 to include the changes made to Map 11 — Sheet 1. <br />Specifically, the RDA Belt Addition and the Explosives \Chemicals Storage area <br />should be added. <br />NECC — Please refer to the enclosed updated table 19. <br />2. DRMS — Please update page 2.05 -7 to describe the RDA Belt Addition. <br />NECC — Please refer to the enclosed page 2.05 -7d <br />3. DRMS - Please submit an engineered design for the proposed road accounting for the <br />variance from the standard design specification. Per Rule 4.03.1 (1) (e), "Alternatives <br />to the design criteria and specifications of 4.03.1 (3) may be utilized after approval by <br />the Division upon a thorough analytical demonstration by a qualified registered <br />professional engineer that such alternatives will be as environmentally sound as those <br />resulting from haul roads complying with the requirements of 4.03.1 (3) and that the <br />alternatives meet such other criteria as are necessary to achieve reclamation in <br />accordance with the requirements of this rule, taking into consideration physical, <br />climatological and other characteristics of the site. Alternatives to the design criteria <br />and specifications of 4.03.1(3)(e) may not be utilized unless, in addition to the <br />referenced demonstration, appropriate engineering tests establish compliance with a <br />minimum static safety factor of 1.3. ". The design should include discussion as to the <br />maximum size of vehicles that will use the road. <br />NECC - The design of the road is explained beginning on page 2.05 -7a. A Haul <br />Road Certification Statement is enclosed. <br />4. DRMS - Pages 2.05 -7a and 2.05 -7b describe the haul road design that was approved <br />with TR66. Please update pages 2.05 -7a and 2.05 -7b to reflect the new design. <br />NECC - Pages 2.05 -7a through 7d were revised reflect the new design. <br />