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<br />s ion <br />2.05.3(6)(b) Page 5-20(1) -Four foot lifts in reality do not compact. The Division <br />strongly recommends lifts of no more than 2 feet and preferably l foot. <br />Response <br />OEI believes that practically the lifts will be deposited in approximately 2 <br />foot lifts due to the size of loads and type of materials used. However, <br />they elect for the statutory minimum to be four feet. <br />uesti n <br />2.05.3(8) Page 5-22(5) this paragraph states that "records document no problems <br />with acid mine drainage in the Durango area." This is in error as drainage <br />from the Victory 1 and Victory 3 portals of the Peerless mine are highly <br />acidic therefore, the spoils and coal refuse/waste do pose a potential for <br />acid mine drainage. <br />Response <br />The Peerless mine has been discussed previously. The spoil from coal will <br />be placed above the drainage level. See Figure 5-4. Any acid drainage <br />• will be treated with limestone or other chemicals to eliminate any acid <br />discharge. <br />s ion <br />2.05.4(2)(b) The reclamation plan is broken into 3 parts; current disturbance, maximum <br />disturbance, and the final open pit area. Bonding has been calculated for <br />each scenario, however, numerous problems exist. IN November 1989, <br />the Division calculated the bond to reclaim the existing site at <br />$1,125,300.00. <br />Under the worst case scenario, a pit with a 250 foot highwall and <br />somewhere in excess of 1,000,000 cubic yards is to be left as a pond, yet <br />no justification for the pond exists other than it would be beneficial to <br />wildlife. In order for a pond of this magnitude (+20 acre feet) to be left, <br />it must be demonstrated that: <br />1. Surface and ground water rights are obtained. <br />2. The ground water ^ow would be sufficient to fill and maintain the pond <br />year in and year out. <br />3. The underlying strata can hold the water and inflow would exceed the <br />evaporative rate. <br />4. There would not be any highwalls above the water line. <br />. 5. Fish and wildlife matters would have to be readdressed. <br />6. Justification as [o why the mine plan would be changed to leave the <br />pond rather Than continuing on with the planned mining. <br />7. Justification for modifying the AOC fur final reclamation. <br />-9- <br />DcC g ~ 1992 <br />