REV14539 - Laserfiche WebLink

Home Browse Search

mo-. nr,~e serd~y Colorado Drvirian afrl-[iner'a!c and Geology rblmrh 26, 2004 Pogr i In response to the Division's concerns re: clazification of updates/adjustments in the mining and reclamation schedule and justification of the request for a variance from the contemporaneous reclamation requirements (per Rules 4.14.1 (c) and 2.05.4 (c)(2), as referenced), SCC has reviewed and revised the Coal Resource Recovery (Tab 12), Reclamation Schedule (Tab 19), and BackElling and Grading (1'ab 20) documentation. Exhibits 12-1A, Operation Plan, and 19-1t\, Baekfilling and Rough Grading, have been revised and updated to identif}' annual sequencing of mining and reclamation activities through the end of the mine life. Anew map, Exhibit t9-1B, Fina] Grading, has been developed to show the anticipated timing and sequence of final grading activities and postmining drainage channel construction. These revisions provide the narrative, mapping, sequencing, and acreage information rcquired under Rules 2.05.3(2)(a) and 2.05.4 (c)(2), and the justification for variance required under Rule 4.14.1(c). Comment 1b: lY/ith the IR-20 submittal, SCC afro added language to page 5 of Tab 79 indicating the follawdng: `To gel reclamation back on schedule, SCC bar in the interim, rented lwo additional do.~ers that are dedttated to the backfzlling and grading activities". With TR-25, the commitment to renting additional do~err do meet reclamallon requirements has been removed from the permit language. Response lb: Due to the additional support earthwork requirements imposed by increasing overburden depths, steeper and narrower pits, and resultant material re-handle requirements, SCC rented two dozers and scheduled additional dozer shifts during 2003 to meet reclamation requirements. The commitment to rent additional dozers, referenced in the division's comment has been fulfilled and SCC has no current or future plans to supplement their existing equipment fleet, therefore the previous temporary commitment has been eliminated from the permit discussion. Comment Z.• Please provide the location of the proposed haul road to and from the Valora Pit area. The haul road should be Lndicated on appropriate maps by a dashed line. Response: Map 12-1, Operations Plan -Mining, has been revised to show current and proposed road locations, including the proposed in-pit haul road from the Valora Pit. Comment 3: The Division doer not typically allow revision to the approved postmining contours bared on the ability or inability of the operator to meed the schedule of the approved backfzll and grading plan. SCC must demonstrate compliance with all aspects of Rule 4.14.2, General Grading Requirements. 7 be revised postmining topography, as shown on Exhibit 20-2, indicates that the proposed topography is steeper and considerably more material wall be left in place in the location of the former Valora Pit. It also appearr that there may be a remnand bighwall left in place at this location. In accordance with Rule 4.14.2(1)(6), fn all rases the bighwall shall be eliminated, unless retention of a bighwall is speajrcally approved by the Division pursuant to 4.14.1(210 or (~. Please provide a demonstration showing that the bighwall will be eliminated and that the revised backfrll and grading plan including the postmining topography will be in compliance with Rule 4.14.2(1)(6). Response: The primary reason the postmining topography in the North end of the Valora Pit has been modified is to accommodate both ongoing backfilGng and cough grading in this area and establishment of the alternate haul road neccssar}' to replace the lower portion of Haul Road D, which has been impacted by the stability problems above Pond 12. By shifting the majority oEPostmining Channel YPM-7 north, above the proposed haul road connector, backfilling, rough grading, and drainage channel consauction in the extreme north end of the Valora Pit can proceed without further delay.