2018-09-04_REVISION - C1980007 ‎(11)‎

• Permit No: C1980007
• IBM Index Class Name: Revision
• Doc Date: 9/4/2018
• Doc Name: Proposed Decision and Findings of Compliance
• From: DRMS
• To: CAM Mining, LLC
• Type & Sequence: PR15
• Email Name: LDS
• Media Type: D
• Archive: No

53

The Division has granted a variance from Rule 4.10.4(5), to cover the LRP with a
minimum of four feet of non-toxic and non-combustible material. The operator was
able to demonstrate that there would be no expected detrimental effects on revegetation
and that the probability of spontaneous combustion occurring is very low with a
proposed soil cover of 18 to 24 inches. A satisfactory revegetation, erosion, and
spontaneous combustion monitoring plan was proposed for the LRP. Also, contingency
plans were proposed for all three concerns in the event of failure or poor reclamation
success. Therefore, upon reclamation of the LRP, the operator will cover the pile with
18 to 24 inches of topsoil and subsoil. For more information, please see information
regarding Technical Revision No. 53.

The West Elk Mine was permitted to accept and dispose coal mine waste from other
neighboring operations, if comparable in characteristic to MCC's refuse. In the past,
MCC has accepted sediment clean-out from the Terror Creek Loadout and development
waste from Bear Coal Company [4.10.1(2)].

The LRP is inspected quarterly by a qualified professional specialist under the direction
of a professional engineer, experienced in construction of similar earth and waste
structures. Features inspected are erosional, drainage, structural, reclamation, and
general compliance and other miscellaneous features [4.10.2(1)].

In January of 1997, MCC submitted an application for TR-79 which proposed the
addition of the RPE on approximately 20 acres immediately east of the LRP, on the
opposite (east) side of Sylvester Gulch. TR-79 was approved in 1997. The plan is to
develop the pile in stages. Phase I is the buildout which involved the removal of topsoil,
initial grading, construction of a dual-cell sedimentation pond, liner, and underdrains
along with run-off control. Phase II was the initial refuse emplacement. Phase III will
involve the main build-out as the pile will proceed up the hillslope to the north at a slope
of 2.5 to 1. Sediment controls will be extended to the west, south and east sides.
Ultimately Phase IV will be the completion of the pile with a capacity of 1,384,102
cubic yards total.

The sedimentation ponds and initial run-off control berms and ditches were completed
prior to the beginning of Phase I. Topsoil was placed north of Highway 133 in an area
known as the north soil storage area (NSSA). Subsoil from Phases I and II were used in
the development of the Sylvester Gulch facilities area (PR-7). Subsoil removed in
phases III and IV will be sufficient for reclamation of the RPE area itself and will be
placed in a stockpile to be determined prior to the beginning of Phase III.

The RPE area of Phases I and II is lined with high-density polyethylene liner. An
underdrain, designated as a rock drain, is used for collecting refuse fill drainage. The
liner will allow subsurface water to migrate into the rock drain system and be routed to
the RPE sedimentation pond. Phases III and IV subsurface will not be lined because of
the steeper slope grade (2.5H:1V) and the greater clay content of the colluvium.

The reclamation of the RPE was approved with an average total of 18 to 24 inches of
subsoil and topsoil. A variance to cover the LRP was approved through TR-43 in July,
1987. That variance was applied also to the RPE. As the RPE is graded and covered