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New Elk Mine (C-1981-012) <br />a. Page 1 through 74 are numbered as such in the top right corner, with a footer in three parts: "Section 2.05"; <br />[Revision]; [Date]. <br />b. Pages 75 through 103 are numbered at the bottom of the page as "2.05-61" through "2.05-87". A revised date is <br />also shown at the bottom right corner of these pages. <br />c. Pages 104 through 114 are numbered "88" through "98" in the top right corner, with a footer in three parts: <br />"Section 2.05 Part 2"; [Revision]; [Date]. <br />d. Pages 115 through 157 comprise the figures for section 2.05 preceded by a Figures Table of Contents. The pages <br />are not numbered but are identified by figure number. <br />e. Please correct these pagination errors. <br />Section 2.05.3(4) describes ponds, impoundments and diversions within the permit area. Towards the end of the <br />section the discussion concerns water within the mine workings, and was written in the future tense about the <br />planned reopening of the mine. <br />12. Please update the discussion to reflect actual conditions encountered during the reopening of the mine as well as the <br />current drainage plan within the mine. <br />An assessment was completed on behalf of NECC by Arcadis. Although the assessment was not required by the <br />Division, a copy of it was forwarded to the Division (email correspondence from Ron Thompson, May 6, 2014). <br />The assessment is informative and would be of benefit to the PAP; reference to it could be made in the discussion <br />in section 2.05.3(4), and the document itself added to the PAP as an exhibit. <br />13. Please add this information to the PAP or comment on why it is excluded. <br />Section 2.05.3(8) describes the handling of non -coal processing waste. The text refers to a disposal area shown <br />on Map 21 (and also on Map 12). Observations during recent inspections suggest that non -coal waste is now <br />collected in dumpsters and hauled off-site. The disposal area is shown within the boundary of the sediment drying <br />area on Map 12, which seems to be contradictory. The scrap storage area referred to in the text is not shown on <br />Map 12. <br />14. Please revise section 2.05.3(8), and (if necessary) Maps 12 and 21, to reflect current practice for the handling of non - <br />coal waste. <br />Rule 2.05.4(2)(g) requires that the reclamation plan includes: <br />A description, including appropriate cross sections and maps, prepared in accordance with 2. 10, of the measures <br />to be used to seal or manage mine openings, and to plug, case, or manage exploration holes, other bore holes, <br />wells, and other openings within the proposed permit area, in accordance with 4.07. <br />15. To this end the Division suggests that a summary of the information concerning all boreholes, slurry wells, <br />groundwater monitoring wells and other drill holes be consolidated into a single table in the PAP, with reference <br />made to the exhibit(s) where detailed information is to be found (concerning completion, abandonment, etc.). <br />Please comment. <br />Rule 4.30 Cessation of Operations <br />Rule 4.30.1(2) requires that NECC notify the Division if there is to be a temporary cessation of mining and <br />reclamation operations for a period of 30 days or more. It is apparent that mining operations have ceased <br />temporarily, as has been detailed in inspection reports, but it appears that activity related to reclamation is ongoing. <br />16. Please advise the Division as to the intentions of NECC regarding ongoing activity over the coming permit term. <br />Such a statement is in no way binding but will be helpful as a record to explain the status of the permit. <br />17. The page numbers in the Table of Contents needs to be updated to match the body of the report. <br />18. Page 2.05-89 in the PAP discusses water rights related to groundwater. It is unclear to the Division if/where <br />surface water rights are discussed. <br />19. It is unclear to the Division where the PAP explains the NECC process for monitoring sediment levels in ponds. <br />This is highly important and should be clearly described. <br />New Elk Mine C1981 012 Mid Term 7 Page 12 <br />Date: August 2016 Prepared by: R. Reilley File location: M:\Coal\Findings <br />