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plant. The cover letter to the application for Technical Revision No. 110 indicates that the coal - <br />to -gas plant will be constructed on the site of the "clean coal pile" once coal there is "depleted." <br />If, by this change, Bowie is eliminating its ability to store clean coal for shipment to power <br />plants, it is effectively getting out of the mining business and getting into the gas, diesel, and <br />electricity business. This would constitute a "significant alteration [] in the surface coal mining <br />... operations" at the site, requiring a Permit Revision. Colorado coal mining regulations, Section <br />2.08.4(1)(a). <br />The process for approving a Permit Revision is much more rigorous than that for a <br />Technical Revision. A Permit Revision must comply with the notice and hearing requirements <br />under Section 2.07 of the Colorado coal mining regulations, whereas a Technical Revision is <br />simply subject to a nominal comment period. Here, it is critical that DRMS subject the proposed <br />and highly speculative revision to an appropriate level of scrutiny and review. As it stands, the <br />proposed revision would require major changes in Bowie's mining and reclamation plans, and <br />that construction and operation of the "DAXIOM Plant" poses significant risks and uncertainty <br />around whether Performance Standards will be met. If DRMS chooses to continue processing <br />and reviewing the proposed revision, the agency must undertake a full Permit Revision.' <br />2. The Application Fails to Demonstrate How Performance Standards Will be Met <br />The application submitted by Bowie Resources also fails to demonstrate that all <br />applicable Performance Standards under Colorado coal mining regulations will be met with <br />regards to the operation and reclamation of the "DAXIOM Plant." In particular, the application <br />does not appear to provide information to demonstrate compliance with the following <br />Performance Standards: <br />' The application includes a 1 -page "Reclamation Estimate," but this estimate does not address <br />many potentially significant impacts, such as ash disposal. And what estimates are provided are <br />questionable or contradicted by other information in the application. For example: <br />- The estimate fails to explain why the cost estimate for destruction of the conveyors, for <br />reclamation, is zero dollars. <br />- The "Reclamation Estimate" includes a line for "Task Description" which describes the <br />task as: "Temporary Culvert T-176 at gob pile #2." DRMS must explain or correct this <br />description. <br />- The "Reclamation Estimate" contains an estimate for "Demolish[ing] DAXIOM Plant <br />& Ash Storage" describing the dimension of those facilities as 100x30x43. The proposed <br />amendment to Bowie's permit describes the DAXIOM plant as twice as wide: "Five DAXIOM <br />skid mounted units occupy and [sic] area 60' wide by 100' long x43' high." If the facility has <br />twice the square footage as that used to calculate the cost of reclamation in the estimate, the <br />actual cost of reclamation may be double the current estimate. <br />- The application does not disclose whether plant operations will require electricity, <br />power poles, or other transmission facilities that will result in ground disturbance and that thus <br />ultimately must be reclaimed. <br />El <br />