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2010-04-21_REVISION - C1982056
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2010-04-21_REVISION - C1982056
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Last modified
8/24/2016 4:08:29 PM
Creation date
4/21/2010 1:25:44 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
REVISION
Doc Date
4/21/2010
Doc Name
Adequacy Responses
From
Twentymile Coal Company
To
DRMS
Type & Sequence
RN5
Email Name
JHB
Media Type
D
Archive
No
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and it is the Division's understanding that based on this agreement, there are no water users on <br />either of these segments downstream of TCC mine water discharge for domestic purposes. <br />Therefore, the Division believes that a sulfate standard does not limit TCC's volume or quality of <br />mine discharge. However, other stream standards do apply as shown in the tables for other <br />constituents. The Division finds that it is appropriate for TCC to review that section of the permit <br />that deals with discharge limits imposed on TCC based on conductivity and sulfate ratios, and <br />propose revisions based upon the this updated information. <br />Response: The referenced permit section has been reviewed and revised, as appropriate, consistent <br />with current regulatory and discharge requirements and considerations. At present, TCC is continuing <br />with monitoring under the monitoring plan and timetable outlined in both our hydrologic monitoring <br />plan and the related PAP text. We anticipate that we will revised our existing CPDS Permit to <br />eliminate water-supply related monitoring, and once approved, will make appropriate revisions to the <br />PAP. Copies of the revised PAP materials accompany these responses for insertion/replacement in the <br />PAP. <br />18) Due to concurrent permitting action that occurred recently. There appears that there is more than <br />one version of Map 24. Please make sure that all the revisions that were approved are included on <br />one version of Map 24. It appears that there is not one version of Map 24 that incorporates <br />changes approved during MR61, MR222, and MR228. Please review the most recently approved <br />version of Map 24 and assure that all previously approved changes are included. <br />Response: The four current sheets for Map 24 (Sheets 1 through 4) have been reviewed and compared <br />against the Map 24 revisions submitted and approved with the referenced permit revision submittals. <br />MR61 (1991) was for development drilling, and is so old that we were unable to find documentation <br />for this revision. The Washplant Powerline is shown on Sheet 1/4 of Map 24 (MR07-222, 08/23/07). <br />The 10-Right Dewatering Borehole No. 2 is shown on Sheet 2/4 (MR08-228, 06/02/08). The latest <br />versions of the individual Map 24 map sheets are; Sheet 1/4 - TR09-69 dated 07/24/09; Sheet 2/4 - <br />MR09-238 dated 09/30/09; Sheet 3/4 - MR09-236 dated 02/22/09; and Sheet 4/4 - TR09-70 dated <br />11/18/09. <br />19) On page 2.04-42 "Known uses of Ground Water", the text refers to "Exhibit 6H, Summary of <br />Ground Water Rights". This is an incorrect reference. Exhibit 6H is "Class III Cultural <br />Resources Inventory". Please correct the reference to direct the reader to the appropriate location <br />for Groundwater Rights. <br />Response: The identified reference has been corrected to refer to Table 9, Summary of Groundwater <br />Rights, which was recently updated in conjunction with PR09-08. Copies of the revised PAP materials <br />accompany these responses for insertion/replacement in the PAP. <br />20) RCE _ $7,832,530.89. TCC's response to Adequacy questions Nos. I and 2 will require revision <br />to task no. 069, which will result in a change to the Reclamation Cost Estimate total. Please find <br />copies of the Division's estimate attached to this letter. <br />The Division currently holds two bonds that total $7,933,169.00. The required liability upon the <br />approval of MR233 (December 15, 2008) was $7,875,818.84. The updated estimate represents a <br />reduction of $43,287.95, or -0.5%. <br />Revisions approved since that last RCE (MT2005) have been incorporated into the RN5 RCE. <br />TCC has not requested bond release for any tasks. Although fuel costs and operating costs have <br />increased as reflected in increased costs for many of the tasks, some costs have decreased. Well <br />sealing costs have gone down due, in part, to the method the Division is using to conduct the well
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