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TWENTYMILE COAL COMPANY - FOIDEL CREEK MINE (C-82-056) <br />PERMIT RENEWAL RN08-05 <br />TECHNICAL ADEQUACY RESPONSES <br />1) The Division was unable to find in TCC's Reclamation Cost Estimate (RCE) Appendix A costs to <br />cover the total acreage of the Refuse Disposal Area (RDA). The cost for covering 15 acres of <br />disturbance is included, Appendix. A page 54. However, the acreage of the entire RDA is <br />approximately 58 acres. TCC needs to provide reclamation cost estimates for covering the entire <br />RDA. <br />Response: The bonding calculations on page 54 (TR95-21) refer to the "Waste Pile 6925 Terrace" <br />area, and associated access road. The Division is correct in noting that the referenced acreage(s) (15 <br />acres for cover reapplication and 18 acres for topsoil replacement) fall short of the total permitted <br />refuse pile area. Given the reference to a discrete area, it seems reasonable to assume that the <br />calculation on page 54 relates to only a portion of the overall refuse disposal area. On pages 1 through <br />If of Appendix A, reclamation costs are calculated for the "Waste Rock Disposal Area" (TR97-21) for <br />approximately 431,000 cy of material and 29,000 cy of topsoil material (460,000 cy total). Given <br />some uncertainty as to whether the referenced "Waste Rock Disposal Area" is the same as the refuse <br />disposal area, it is unclear as to whether or not these calculated reclamation monies apply to the refuse <br />disposal area, or some other area. <br />It is important to note that the most recent update (01/16/09) of the Division's CIRCES reclamation <br />cost estimate includes (Tasks 069 and 071) over $530,000 for placement of soil and cover material on <br />the existing; refuse disposal area. Based on placement depths and the volumes presented in the <br />Division's bond calculations 319,000 cy cover material and 155,000 cy of soil material, 474,000 cy <br />total), these bond monies are more than adequate to address the entire refuse disposal area. Given <br />uncertainties with the historic bond calculations provided in Appendix A, and that it appears that the <br />Division's current bond calculations (and the current bond surety) include adequate funds to address <br />reclamation of the entire refuse disposal area, TCC seeks some guidance on how to address this <br />comment.