2016-10-19_REVISION - M1980244 - Laserfiche WebLink

Home Browse Search

Follow-up Adequacy Review (AM-11) – Elliott Russell October 18, 2016 Page 4 of 5 40. Response to Adequacy Item 40 is inadequate. The response to Adequacy Item 40 removes the statement that access to the tops of highwalls should be restricted. The intent of this statement was to specify how wildlife would be protected and removing it does not address the protection of wildlife. Note, upon the completion of mining and reclamation, the Applicant has committed to installing a 6-foot high (minimum) chain link fence around the crest of the mine areas where highwalls of greater than approximately 100 feet remain. Please update the Wildlife Protection Plan to include these details. In accordance with Rule 3.1.8(1), please provide details on how the Applicant will protect wildlife from encountering the hazard of a highwall during the mining operation. 44. Response to Adequacy Item 44 is inadequate. The Division requests the Applicant commit in writing to route a copy of Wildlife Incident Reports to the Division of Reclamation, Mining and Safety. Additional Adequacy Items: 6.4.5 Exhibit E - Reclamation Plan 49. Within the Security and Signs section of the Project Description (Volume I), the Applicant states that upon completion of mining and reclamation, a 6-foot high (minimum) chain link fence will be installed around the crest of those portions of the mine areas where highwalls of greater than approximately 100 feet in depth exist at the top of the mine area. In accordance with C.R.S. 34- 32-102(1), Rule 3.1.8(1), and Rule 6.4.21(18), please either provide a technical justification and demonstration that highwalls less than 100 feet are not considered a hazard and that no fencing is required OR commit to installing the fence around the crest of any highwall that remains as a permanent feature of the reclamation. Please identify the location of the all fencing on the Drawing F-1, similar to Drawing CCVSA11-3 in Exhibit L. If necessary, please update the Exhibit L reclamation cost estimate to account for any additional fencing requirements. 6.4.6 Exhibit F- Reclamation Plan Map 50. The updated Drawing F-1 (REV: 3) depicts various facilities around the Cresson Project and an access road through the East Cresson Mine (Wildhorse Extension) area. The Division believes this is an error because the road and one of the facilities is located across a highwall. Additionally, the Applicant stated in the response to Adequacy Item 33, should certain road corridors or facilities be intend to remain, a revision to the reclamation plan would be submitted. In accordance with Rule 6.4.6(a), please remove the facilities around the Cresson Project and the Ironclad access road on Drawing F-1 and re-submit the map for further review. 51. The Applicant has depicted Restricted Access areas on Drawing F-1. Please explain why the vertical highwall along CR 82, northwest of the East Cresson Mine (Wildhorse Extension), is not included in this restricted access area or revise and re-submit the map for further review in accordance with Rule 6.4.6(a). Furthermore, pursuant to C.R.S. 34-32-102(1), please