2016-02-25_GENERAL DOCUMENTS - C1982056

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majority of the adequacy review issues were addressed. On December 8, 2015 the Division sent TC a second adequacy review letter. This letter requested an updated hydrologic monitoring site map based on their response to the adequacy review; also, several minor textual issues were identified. The Division received TC's response to the second adequacy review letter on February 9, 2016. The response letter addressed all of the adequacy review issues identified by the Division. Permit Acreage Discrepancy The Division's permit system records currently indicate the permit area for the Foidel Creek Mine is 20,100 acres. TC indicated in the PR -11 application that the current permit area should be 22,447 acres. During the review of PR -11, the Division investigated this discrepancy. The large difference in permit acreage the Division has been recording and what TC has determined seems to have originated with Permit Renewal Application No. 3 (RN3), Permit Revision No. 5 (PR5) and subsequent revisions. It appears the Division requested the permittee to clarify the permit acreage with RN3 and there was a decision made on what the permit area should be. However, it is unclear what the final decision was, based on the information in the Division's file for RN3. PR5 and RN3 were under review at about the same time period and PR5 was approved two months after RN3 was approved. When PR5 was approved, permit page 2.01-4 was updated with a revised permit area of 23,040.9 acres. Technical Revision No. 33 (TR33) was submitted during the review of PR5 and was approved prior to PR5 and added 7.2 acres to the permit area. The date on revised page 2.01-4 is prior to the date TR33 was submitted. TR33 did not update page 2.01-4 so it is likely the 23,040.9 acres from PR5 does not include the 7.2 acre addition from TR33. By adding the 7.2 acres, the total permit area should have been 23,048.1 acres with the approval of PR5. The Division's decision form does not appear to have been updated with the correct permit area when RN3/PR5 was approved. PR6 requested to increase the permit area by 560 acres. This revision was approved but it does not appear the Division's decision form accounted for the increase in acreage. With the approval with PR6, the permit area should have been 23,608.1 acres (23,048.1 + 560 acres). Then, TR51 reduced the permit acreage by 1,320 acres. During the review of TR51, the permittee submitted MR205 which should not have changed the permit acreage. When the Division approved MR205, the decision form indicated a permit area that was 1,320 acres less than the previously approved permit area. Subsequently the Division approved TR51 and reduced the permit area again by 1,320 acres. Given this, it appears the 1,320 acres was inadvertently reduced twice from the Division's records. When TR51 was approved, the permit acreage should have been 22,288.1 acres. Subsequently, with TR82, the Division approved a 160 acre increase in the permit boundary yielding a permit area of 22,448.1 acres (22,288.1 + 160 acres). PR -11 requests an approval of a new 160 -acre increase in the permit area. By adding 160 acres to 22,448.1 acres, the total permit area should be about 22,608.1 acres. PR -11 indicates the permit area should be 22,607 acres. The 1.1 difference in acreage is likely due to a rounding error. Given these findings, with the approval of PR -11, the Division will increase the permit area in our electronic tracking system (20,100 acres) by 2,507 acres to account for the discrepancies discussed above (2,347 acres) and the new 160 acres proposed with PR -11. With the approval of PR -11 the permit area will be 22,607 acres. Publication of this proposed decision initiates a thirty -day public comment period. Provided there are no objections to the decision, the proposed decision will become final at the close of the comment period. Foidel Creek Mine 7 February 25, 2016