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L D o <br /> Division of Reclamation, <br /> A&ID-,da <br /> Mining and Safety <br /> Department of Natural Resources <br /> July 17, 2019 <br /> Mr. Tom Bird <br /> GCC Energy, LLC <br /> 6473 County Road 120 <br /> Hesperus, CO 81326 <br /> Re: King Coal Mine, Second adequacy letter for TR-27 <br /> Dear Mr. Bird: <br /> The Division of Reclamation,Mining and Safety(the Division) received GCC's response to our TR-27 <br /> preliminary adequacy review. Thank you for your response letter dated June 25,2019. Your responses <br /> addressed many of our issues,but we ask that GCC staff respond to the following follow-up adequacy <br /> items. <br /> Section 2.05 <br /> 1. No additional response required. <br /> 2. In the discussion of fill material(Section 2.05.4), GCC has added volume calculations. The <br /> Division recommends further discussion on the source (or sources) for this material. Even if <br /> GCC chooses to not put this information in the PAP, it will be necessary for the Division to <br /> produce an accurate Reclamation Cost Estimate. <br /> 3. No additional response required. <br /> Appendix 10 <br /> 4. No additional response required. <br /> 5. No additional response required. <br /> 6. The Division has the following follow-up comments. <br /> a. In the adequacy response,GCC states that the currently proposed underdrain sizing is based <br /> upon the original refuse pile underdrain analysis in Appendix 10(1) and the July 2014 <br /> Trautner Geotech report. This Trautner report needs to be submitted as part of TR-27. <br /> Also, as applicable, please edit the Trautner report (an addendum would suffice) to <br /> agree with the alternative design for TR-27. <br /> b. The waste bank proposed in TR-20 is considerably smaller than the Lower Refuse Pile <br /> proposed in TR-27. To address the difference in size, it appears that GCC used a linear <br /> relation between the recommended underdrain size (from Trautner report) and the pile <br /> footprint area to size the proposed underdrain in TR-27. While this approach may be <br /> acceptable, this needs to be clearly described in a submittal for the Division's review. <br /> 0 <br /> 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br /> Jared S. Polis, Governor Dan Gibbs, Executive Director Virginia Brannon, Director '�1876� <br />