2015-05-12_REVISION - C1981014 - Laserfiche WebLink

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RESPONSES TO TECHNICAL REVISION NO. 45 (TR -45) PRELIMINARY ADEQUACY LETTER This will serve as the EFCI response to the CDRMS PRELIMINARY ADEQUACY RESPONSE letter dated 9 April 2015. In order to ensure that each and every concern contained in this letter is addressed, the concern expressed in the CDRMS's letter will be repeated followed by our response. Concern. # 1. Please use consistent acreage values when referring to the approved reference area. On page 2.04.10 -6 (approved TR -39), revised dated December 3, 1013, EFCI reported acreage values for the respective reference areas. Weighted % Grassland (Refuse Pile reference area) 2.80 acres 52.93% PPJ (Plot B Portal area) 0.42 acres 7.94% New Portal Area Reference area (PJ) 2.07 acres 39.13% Total reference area acres 5.29 acres Page 4 of the TR45 application letter provided the following acreage figures for the representative reference areas: Grassland reference area 2.80 acres 58.6% PPJ (Plot B- Portal area 0.29 acres 6.0% New Portal Area Reference area (PJ) 1.69 acres 3.54 % [sic] value is actually Total Reference area acres 4.78 acres 35.36%) The New Loadout reference area was approved as 1.02 acres (TR41, approved November 6, 2014 page 2.04.10 -5b). Approved permit pages 2.04.10 -5 through 2.04.10 -5b define that the mine area reference area data will be combined based on average weighted values, while the load out reference area will be used for comparison to the reclaimed area load out. The New load out reference area should not be included with the acreage combining of the mine area reference area. The acreage values of the approved reference areas must stay consistent. Please continue to use consistent acreage values as approved. If a correction to the surveyed acreage is necessary, then the respective pages, with an explanation of the need for the correction is required. Response: The acreage figures reference by the CDRMS in connection with the Old Portal RA (0.42 acres) and New Portal RA (2.07 aces) represents the figures used at the start of the TR39 permit revision process. Subsequent to these original figures being calculated, the CDRMS directed EFCI to delete a small area of disturbance in the southern portion of the proposed New Portal RA (see adequacy response letter from Janet Binns to George Patterson dated 8 September 2013 in the CDRMS Laserfiche TR39 file), which was subsequently removed from the original area making this RA 1.69 acres in size. Also, Doug Corley relocated, using his GPS survey unit, the metal t post corresponding to the SE corner of the Old Portal RA and came up with the