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G / fg0 00 7 <br />mA-364- <br />/ICw? Gd?res?`Q <br />Kaldenbach, Tom <br />From: Kaldenbach, Tom <br />Sent: Friday, April 09, 2010 12:44 PM <br />To: 'Welt, Kathy <br />Cc: Hernandez, Daniel; Nolte, Doug <br />Subject: RE: West Elk Mine (C-80-007), MR-364 <br />Kathy, <br />For the revision application to be found complete it will need to provide information that demonstrates the proposed <br />work will comply with the following Rules. Your previous TR-111 application (and other MDW TRs) provided this <br />information. <br />Right of entry (2.03.6(1)) <br />Cultural resources (2.04.4) <br />Fish/wildlife information (2.04.10, 2.04.11, 2.05.6(2) and 4.18) <br />Maps and plans (2.10) <br />Light-use roads (4.03.3) <br />Topsoil (4.06) and topsoil markers (4.02.7) <br />Water quality protection (4.05.2) <br />Impoundments (4.05.9) <br />Sediment control (4.05.5) <br />Stream buffer zones (4.05.18) <br />Reclamation plan (2.05.4) <br />Backfilling/grading (4.14) <br />Revegetation (4.15) <br />Drillhole sealing (4.07) and DRMS Guideline for methane drainage wells <br />Bond amount (3.02.2) <br />A TR rather than an MR is required because the proposed methane drainage well (MDW) pad is on USFS land outside the <br />drill pad polygons and road corridors approved in PR-14. I do not know of a permit commitment or stipulation that <br />requires it to be a TR. <br />Requiring a TR for the work proposed in MR-364 would be consistent with the DRMS staff policy as it was presented to <br />the Colorado Mined Land Reclamation Board in a hearing on July 9, 2008 regarding TR-111 (Panel E-1) MDWs. DRMS <br />staff explained their policy that a significant change from the TR-111 "conceptual plan" would require a TR, rather than <br />an MR (please refer to Item 4 on first page of attached copies of pages excerpted from staffs hand-out to the Board; <br />MCC's legal counsel a copy before the presentation). The "conceptual plan" referred to the drill pad polygons and road <br />corridors shown on MCC's Map titled E Seam MDW Drilling in tab TR-111 of Exhibit 80. <br />Approving the work proposed in MR-364 as an MR would be a deviation from a policy of requiring a TR for significant <br />differences from an MDW conceptual plan on USFS land. The polygon/road corridor plan for the panels that are the <br />subject of MR-364, Panels E3 and E4, was approved in PR-14. MR-364 proposes a drill pad outside the polygons that <br />were approved in PR-14 and, therefore, would be a significant change from the plan approved in PR-14. To remain <br />consistent with the DRMS staff policy previously presented to the Board, the work proposed in MR-364 needs to be <br />submitted as a TR. <br />Tom Kaldenbach <br />Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman St., Room 215