2021-09-02_REVISION - C1981012 ‎(2)‎

• Permit No: C1981012
• IBM Index Class Name: Revision
• Doc Date: 9/2/2021
• Doc Name Note: Adequacy Review No. 1
• Doc Name: Adequacy Review
• From: DRMS
• To: New Elk Coal Company, LLC
• Type & Sequence: PR5
• Email Name: JLE
• Email Name: JRS
• Archive: No

New Elk Mine, PR5 Adequacy Review 1
September 2, 2021
Page 4 of 6
23. Similar to the item above, page 2.04-23 and 24 indicate dewatering of the Allen and Apache coal seams for
mining is not expected to lower water levels in alluvial wells. Please discuss the possible impacts of mining in
the Blue Seam.
24. Please update the NPDES information on Page 2.04-25.
25. Please update Table IOC and page 2.04-25b, 25c, and 25d with current information.
26. Please update permit Section 2.04.7(3) to address mining in the Blue Seam.
Rule 2.05.2 — Operation Plan — Estimated Area for Life of Operation
27. Please revised permit section 2.05.2(1) to include the anticipated annual and total production of coal, by
tonnage.
28. The current approved permit area for the New Elk Mine is 4,201.90 acres with the approval of TR72, and PR5
seeks to increase the permit area by 2,856 acres for a total permit area of 7,057.9 acres. Please update the first
paragraph of proposed revised page 3 with the correct permit boundary acreage.
29. Please update Figure 2 to account for the PR5 proposal.
Rule 2.05.3 — Operation Plan — Permit Area
30. Much of section 2.04 discusses multi -seam mining in various seems, primarily the Allen, Apache, Maxwell
and Blue Seam. For this permit term and for PR5, it appears mining is only projected to occur in the Blue
Seam. Please update Section 2.05.2 to clarify this.
31. Please update the second paragraph of revised page 3 regarding the phases or resuming operations at the site.
As operations have resumed, please update this narrative to discuss the current operation and any additional
work that needs to occur to mine in the Blue Seam.
32. Revised page 3 indicates that no secondary mining is planned in any area where protection from subsidence of
surface structures and the Purgatoire River is required. The cover letter submitted with PR5 indicates that no
secondary extraction is planned. Please revise Section 2.05.3 of the mining plan to clearly indicate that no
secondary extraction is planned.
33. Current page 4 of the PAP of section 2.05.3(1) indicates the mine is not currently active. As production at the
site has now been initiated please revise page 4 of this section accordingly.
34. Current page 5 and 6 of the PAP describe the handling of development waste. According to the last quarterly
inspection report for the refuse and waste piles at the site, refuse placement in Development Waste Disposal
Area 92 has been completed. Please update this narrative about the handling of development waste as
necessary.
35. Proposed revised page 10 indicates the Golden Eagle Fan site's location is depicted on Map 3 and the surface
disturbance boundary is indicated on Figure 2c. The Division could not locate this feature on the proposed
revised Map 3 and the disturbance boundary is not depicted on Figure 2c. Please revise Map 3 and Figure 2c
accordingly.
36. Proposed revised page 10 indicates the Golden Eagle fan site will be returned for use for mine ventilation.
Since the fan site has been sealed, the disturbance area reclaimed and partially released, please provide the
information required by Rule 2.05.3(3) for this facility, and provide a reclamation cost estimate for the closure
of the fan site in accordance with Rule 2.05.4(2)(b).