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Summary of Adequacy Review for TR-102 C'/9~o 007 TR-/oZ Mine: West Elk Date review completed: 9/16/05 Permit No.: C-80-007 DMG reviewer: Tom Kaldenbach Require- ments Requirements complied Comment with 7 (yes Ino i The submittal refers to a Class III Cultural Resource Inventory included in Cultural resources TR-96 for panels 18-24 that covers the drillsite (by Greystone (2.04.4) Yes Environmental, dated 10/O1, Figure 1 of that report). No significant cultural resources were found. The submittal included ri ht-of-en from the USFS. Fish/wildlife The submittal refers to a TESS study included in TR-96 for panels 18-24 information (2.04.10, that covers the drillsite (by Greystone Environmental, dated 10/Ol, Figure 1 2.04.11, 2.05.6(2) and Yes of that report). No species on the state or federal TESS lists were found. The 4.18) submittal included ri ht-of-ent from the USFS. Maps and plans (2.10) es The submittal includes a PE-certified map and wellbore diagram. A 600-ft long ATV trail will be upgraded to a light-use road by dozing. Light-use roads The map in the submittal shows the road will not cross natural drainages, the (4.03.3) Yes overall grade will be less than 10%, and the maximum grade over any 1,000' se ment will be less than 20%. Water bars will be used to control erosion. Topsoil (4.06) and Topsoil will be stockpiled. Stockpiles will be outside of drainages, will be topsoil markers protected from erosion by seeding and other erosion control measures (silt (4.02.7) fences, brush, etc.), and will be marked. Water quality Runoff can be expected to be alkaline with quality similaz to pre- protection (4.05.2) Yes disturbance conditions. The runoff will be too alkaline to form leachates or to mobilize metals. The mudpit will not be part of the sediment control system for the drill pad. The mudpit will be an impoundment (1.04(64)) that will not have a spillway (4.05.9(2)(e), will be located where failure would not be expected to cause loss of life or serious property damage (4.05.9(2)(e), and will be incised. Applying the Galena analysis from TR-101 (based on similar soil Impoundments properties) indicates a 1.3 safety factor will be achieved in the mudpit (4.05.9) Yes constructed under TR-102 (see DMG's memo regarding mudpit slope stability in TR-101 file). The TR-102 submittal contains a PE-certified mudpit design showing the mudpit is sized to hold all of the cuttings from the boreholes and the surface runoff, with 1 ft. of freeboard, from a 25-yr., 24-hr. storm (4.05.9(2)(c)) (see DMG memo to TR-102 file regarding mud it ca aci The drillpad will be an SAE utilizing alternative sediment control measures Sediment control such as slash, silt fence, or straw wattles. SEDCAD runs in the submittal (4.05.5) yes use reasonable curve numbers and other variables. The SEDCAD runs indicate the proposed alernative sediment control methods will effectively control sedimentation. Reclamation plan The plan is to let the mudpit dry out, then fill it with subsoil and compact it; (2.05.4),backfilling/gra scarify or rip the pad/mudpit area; regrade to AOC the pad/mudpit area and ding (4.14), yes light-use road; seed the regraded areas with a seed mix previously approved reve etation 4.15) b DMG. The ad/mud it azea will be fertilized and straw-mulched. Drillhole sealing A mechanical packer will be placed at the lowest possible point in the hole, (4.07) and DMG Guideline for methane yes then the hole will be filled from bottom to top with cement grout placed with drama a wells a tremmie tube. The operator has sufficient bond on deposit to cover the estimated Bond amount (3.02.2) yes reclamation liability created by TR-101 of $3,470 (see DMG's attached reclamation cost estimate).