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Responses to notice of incomplete letter dated March 3, 2010 <br />Question: Please describe in your cover letter discussion why the conveyor cannot be used at <br />present. Describe the problems with getting the conveyor up and running at the moment, the <br />costs involved in getting it operational enough to convey this waste, and the amount of time it <br />would take to get it running. <br />Response: It is planned to re-establish an operational conveyor to the RDA for use throughout <br />the life of the RDA. A drive and a section of conveyor structure including belting has been <br />removed from the site and will need to be replaced. Appropriately sized electric service will also <br />need to be re-established. The sizing of the replacement drive and structure to convey the waste <br />material to the existing RDA for the life of the RDA is currently in the feasibility stage. It is more <br />efficient to put into operation the appropriately sized drive to match the waste generation rate. <br />Delivery times for a new drive are estimated at a minimum of 6 months. The time to install and <br />extend the conveyor structure including installation of a belt feeder is estimated at a month. The <br />bonding in place to dispose of stockpiled unsalable coal as refuse is adequate to cover the cost of <br />refuse disposal. <br />Question: Please include in your cover letter whether NECC would be willing to consider re- <br />designating the access road to the RDA as a haul road. This should include a discussion of what <br />the State Highway 12 crossing safety issues are, and how those could be offset with CDOT- <br />approved highway flagmen or other methods, as appropriate. <br />Response: The option of upgrading the RDA access road to haulroad status to enable haulage of <br />development waste rock material is not under consideration at this time. While it may be possible <br />to upgrade the access road to haulroad status it is not under consideration due to safety <br />concerns. The primary concern is the limited line of site when exiting the access road. NECC is <br />proposing the belt conveyor as the most efficient method of disposal. <br />Question: Please include as permit text detailed time commitments regarding the length of time <br />the underground development waste would reside in the coal stockpile areas. As previously <br />discussed, the mine is currently aware of the need to receive approval for final disposition of coal <br />mine waste in the long-term and is working on the necessary permitting in a forthcoming Permit <br />Revision. The Division's current understanding is the need for temporary storage is a number of <br />months at the maximum. <br />Response: See attached permit text. <br />Question: A discussion in the permit text of how NECC will ensure that the coal mine <br />development waste stored in the coal stockpile areas does not spontaneously combust. If <br />spontaneous combustion is not a problem, the permittee should discuss why not. <br />Response: See attached permit text. <br />Question: A discussion in the permit text of how NECC will ensure the geotechnical stability of <br />the coal mine development waste piles, so that the piles will not fail during a heavy rainfall or <br />snowfall event and end up in the Purgatory River. How high would the material be stacked on the <br />ground, and given the storage locations, is there a need to pile material more than one dump <br />high? <br />Response: See attached permit text. <br />Question: A discussion in the permit text of whether the coal mine development waste poses <br />any potential adverse impacts to surface water and ground water chemistry. Does this waste