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Bowie Resources, LLC <br />Page 4 <br />12/22/2016 <br />8. As noted in adequacy comment number 2, number 3, and number 5, the proposed TR110 <br />application states that the plant will utilize coal waste with no information concerning the origin <br />of the coal waste to be utilized. If it is the case that the origin of the coal waste will be the coal <br />waste piles approved under C-1996-083, Rule 4.11.2 states that before any refuse is removed <br />from the disposal area, approval will be obtained by the Division. If the coal waste to be utilized <br />will be within the Bowie No. 2 Mine gob piles, please submit a plan for the method of removal, <br />with maps and appropriate drawings to illustrate the proposed sequence of the operation and <br />method of compliance with Rule 4.11 with consideration given in the plan to potential hazards <br />which may be created by removal to persons working or living in the vicinity of the structures. <br />Please note that the plan shall be certified by a qualified engineer per Rule 4.11.2. <br />Based on the information submitted in the proposed TR -110 application, the Daxiom process <br />produces a small percentage of inert ash. No discussion is presented in the TR -110 application <br />that provides information as to the disposal or storage of any waste produced by the Daxiom <br />process. Please provide a detailed discussion as to the disposal or storage of any waste that may <br />be generated by the plant and if that waste will require a permit or approval from the Colorado <br />Hazardous Materials and Waste Management Division. <br />10. The Division understands that BRL is the current lease holder for areas in which coal was mined, <br />processed, and the waste disposed of in one of Gob Piles #1, #2, #3, or #4. No discussion in the <br />proposed TR -110 application provided information as to the right to enter and operation <br />information with regard to the re -mining the coal mine waste. The Division understands that <br />information may be required under Rule 2.03.6(1) as to the description of right to enter and <br />operate documents by type and date of execution and an explanation of the legal rights claimed <br />by the applicant of the coal waste. If it is the intention of BRL to utilize coal mine waste from <br />the Bowie No. 2 Mine gob piles, please provide to the Division information which may be required <br />by the BLM in order to re -mine the gob piles for the purpose of the medium for the plant. <br />11. In order for the Division to generate a Reclamation Cost Estimate more information is required. <br />The Daxiom plant facility is currently an unknown facility to the Division. The Daxiom coal <br />gasification plant does not fall under the definition of surface coal mine operations; however, <br />the coal stockpile pad which is required to be reclaimed does fall under the definition of surface <br />coal mine operations and is required to be reclaimed. As such, the facilities constructed on the <br />pad will be required to be reclaimed in order to backfill and regrade the coal stockpile pad. In <br />order to develop a cost to reclaim the pad and demolish the associated structures proposed <br />under TR -110, please submit to the Division information on the Daxiom plant and if the plant will <br />generate any hazardous material upon demolition that may require additional permits in order to <br />demolish, remove, and dispose of. <br />