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TWENTYMILE COAL COMPANY - FOIDEL CREEK MINE (C-82-056) PERMIT RENEWAL RN08-05 TECHNICAL ADEQUACY RESPONSES 1) The Division was unable to find in TCC's Reclamation Cost Estimate (RCE) Appendix A costs to cover the total acreage of the Refuse Disposal Area (RDA). The cost for covering 15 acres of disturbance is included, Appendix. A page 54. However, the acreage of the entire RDA is approximately 58 acres. TCC needs to provide reclamation cost estimates for covering the entire RDA. Response: The bonding calculations on page 54 (TR95-21) refer to the "Waste Pile 6925 Terrace" area, and associated access road. The Division is correct in noting that the referenced acreage(s) (15 acres for cover reapplication and 18 acres for topsoil replacement) fall short of the total permitted refuse pile area. Given the reference to a discrete area, it seems reasonable to assume that the calculation on page 54 relates to only a portion of the overall refuse disposal area. On pages 1 through if of Appendix A, reclamation costs are calculated for the "Waste Rock Disposal Area" (TR97-21) for approximately 431,000 cy of material and 29,000 cy of topsoil material (460,000 cy total). Given some uncertainty as to whether the referenced "Waste Rock Disposal Area" is the same as the refuse disposal area, it is unclear as to whether or not these calculated reclamation monies apply to the refuse disposal area, or some other area. It is important to note that the most recent update (01/16/09) of the Division's CIRCES reclamation cost estimate includes (Tasks 069 and 071) over $530,000 for placement of soil and cover material on the existing refuse disposal area. Based on placement depths and the volumes presented in the Division's bond calculations 319,000 cy cover material and 155,000 cy of soil material, (474,000 cy total), these bond monies are more than adequate to address the entire refuse disposal area. Given uncertainties with the historic bond calculations provided in Appendix A, and that it appears that the Division's current bond calculations (and the current bond surety) include adequate funds to address reclamation of the entire refuse disposal area, TCC seeks some guidance on how to address this comment. 2) It is unclear from the PAP where the balance of RDA cover material will be transported from. Approximately 70,000 cubic yards. of clay material are accounted for on the west side of the RDA (relocated to a permanent excess spoil pile with the approval of MR233). 70,000 cubic yards of material is adequate to cover only 15 acres of the RDA. The RDA is approximately 58 acres. Please provide the Division with a cover material balance for the RDA. Please include haul distances for transporting the material to the RDA. Please provide this information for the currently approved mine plan. (Rule 4.10.4(5)). Response: Based on a footprint of 58 acres, approximately 234,000 cy of cover material would be required to cover the entire existing RDA area. As noted, approximately 70,000 cy of cover material was moved and stockpiled from the southwestern portion of the RDA area under MR08-233. In addition, approximately 25,000 cy of cover material was previously placed on the eastern face of Area 1 of the RDA. With the proposed CRDA Expansion (TR09-67) this material will be recovered and placed on the western side of the regraded RDA. An existing cover material stockpile of approximately 70,000 cy is located in the northern part of the CRDA Expansion area. This material is presently being relocated to a new stockpile location off the eastern edge of the CRDA Expansion area. The combined total for these three cover material stockpile/placement areas is approximately 165,000 cy. The difference between the required and available volumes of cover material is approximately 69,000 cy. TCC only became aware of this deficit during the planning process for the CRDA