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2019-04-22_REVISION - C1981018
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2019-04-22_REVISION - C1981018
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Entry Properties
Last modified
4/24/2019 6:22:31 AM
Creation date
4/22/2019 12:55:37 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981018
IBM Index Class Name
Revision
Doc Date
4/22/2019
Doc Name
Adequacy Review Response
From
Blue Mountain Energy
To
DRMS
Type & Sequence
RN7
Email Name
CCW
Media Type
D
Archive
No
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Item #10 Response: <br />MR -171, submitted June 2017 updated this Section. Specifically, Addendum to <br />Section II.F.4.a(2) Threatened and Endangered Species was added to the permit. <br />Rule 2.04.11— Fish and Wildlife Resources Information <br />11. Please review Section II.G and II.H of the permit and update as necessary. Please <br />ensure that the Threatened and Endangered Species list is updated if necessary. <br />Item #11 Response: <br />No new species labeled as threatened or endangered species have been <br />determined to be present in or near the permit area since the last permit renewal. No <br />update is necessary at this time. <br />Rule 2.05.3 Operation Plan <br />12. Rule 2.05.3(8) — Please update the information in Section III.B.3 in Volume IV of <br />the Deserado Permit as needed. This section contains information on coal mine <br />waste. Please also update Section IV.D, V.D and V.E with any new information <br />as needed. <br />Item #12 Response: <br />Section IV.D has been updated. New Section IV narrative pages have been <br />included in this submittal. All other text sections mentioned in the comment above did <br />not require updates. Map 76 was also updated and provided in this submittal. <br />13. The Division was not able to locate a time table for pond and associated structure <br />removal. Please either direct the Division to this information in the permit or <br />provide revised pages detailing the timeline for removal of ponds and other <br />hydrologic treatment facilities. <br />Item #13 Response: <br />Text has been added to Section V.I.3 that provides a general description of the <br />process for removing and reclaiming ponds and associated structures as requested. <br />2.05.4(2)(b) Reclamation Cost Estimate <br />14. The cost estimate enclosed is based on the Division's best match to the tasks available in <br />CIRCES, and utilizes Unit Costs last updated by the Division in August of 2018. <br />The cost estimate was last updated with Midterm No. 7 (MT7), which resulted in a Surety <br />Reduction (SR -3). Six permitting actions have resulted in a change in liability since the <br />last update, including MR -170, MR -171, TR -71, MR -172, and MR -173. Minor Revision <br />174 (MR -174) was approved in August of 2018, but did not increase the reclamation <br />estimate. No tasks were removed as a part of the update for RN -7. <br />The required surety for the Deserado Mine, prior to the issuance of RN7, is <br />$5,719,215.25. Enclosed is the CIRCES cost estimate for RN7. Based on this estimate, <br />the liability after the approval of RN7 will be $5,801,566. The current bond held for the <br />site is $5,808,383.08. A copy of the new reclamation cost estimate has been attached <br />with this Adequacy Letter for your review. <br />
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