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Page 1 of 1 <br />Gorham, Kent <br />From: Hernandez, Daniel <br />Sent: Wednesday, April 09, 2008 11:04 AM <br />To: Gorham, Kent <br />Subject: Golden Eagle Bond Release Items <br />Kent, with regard to Golden Eagle bond release app SL06 and our findings document, would you mind looking into these <br />items? Thanks. <br />Termination of Water Monitoring/Termination of Submittal of AHRs: I checked with Dave on the termination of <br />water monitoring and termination of submittal of AHRs at Golden Eagle in conjunction with the SL06 application. <br />Dave said it is normally our policy to require permittees to obtain approval for termination of water monitoring via a <br />TR. He did say, however, that at this point, we could handle the termination of water monitoring as best WE! see fit. <br />Do you know of any correspondence in our files between DRMS and Basin/New Elk Coal Company that could be <br />construed as granting approval to the permittee to stop water monitoring (maybe a past AHR review, or a past Mid- <br />Term or Renewal Findings document, or maybe even an inspection report)? If not, do you know of any <br />correspondence that occurred prior to or during the review of the SL06 app that discussed the termination of water <br />monitoring in conjunction with the SL app? <br />• Reclamation of Water Monitoring Wells: Did you mention at last Friday's team meeting that Basin/NECC had <br />already reclaimed all the water monitoring wells it is required to reclaim? Or does the permittee have some wells that <br />still need reclaiming? Will the permittee leave any monitoring wells open permanently? If so, do we know who will <br />hold the well permits for those permanent wells? <br />• "Pollution": Dave brought this up during his recent review of Janet's Grassy Gap TOJ Findings Document. In Rule <br />3.03.2(2) is the requirement that our "evaluation of the reclamation work" consider "whether pollution of surface or <br />subsurface water is occurring, the probability of the future occurrence of such pollution, and the estimated cost of <br />abating such pollution". So if you haven't already looked into this in your review of the SL06 app, please do so. <br />• Groundwater Point of Compliance: Did we ever determine whether the mine needed a ground water point of <br />compliance? If so, did we designate a particular well to be the point of compliance? Is that well now reclaimed? <br />Have we concluded that the mine has not adversely affected the applicable local groundwater standards? <br />• Federal Lands: Golden Eagle is currently classified a "federal" mine. If I remember correctly, this is due to at least <br />one tract of federal coal or federal surface that is (or previously was) present within the mine's permit boundary. At <br />the present time, is there any federal coal and/or federal surface within the current permit area? If so, is this federal <br />coal/surface in the portion of the permit area that is being requested for Phase III bond release? <br />• Release of Liability of Surface Areas Overlying Underground Coal Mine Workings: Will SL06 involve us <br />releasing Basin Resources/New Elk Coal Company from liability of surface areas overlying underground coal mine <br />workings (aka "affected area")? If so, do we know what that affected area acreage figure is? <br />• OSM Concurrence: As this is a federal mine, we will need OSM's concurrence on our proposed decision. This will <br />involve OSM seeking BLM's concurrence. Which BLM office will we inform of our proposed decision? <br />• Remaining Reclamation Liability/Inspection Frequency: Assuming this bond release application is approved, <br />what would the remaining disturbed area acreage and affected area acreage figures be? What would the Phase 1/11/111 <br />liability be for the remaining surface disturbances? I ask this because if all the potential remaining surface <br />disturbances have been Phase II released, we should document in the SL06 Findings that we will reduce our <br />inspection frequency to quarterly Completes once the proposed decision becomes final. <br />• Remaining Bond Amount: Assuming we propose to approve the SL06 app, will the remaining reclamation liability <br />be such that we will be down to the $10,000 minimum amount for bond monies required to be held by us? <br />18 yes-?b-yis <br />4/9/2008