2008-03-05_REVISION - C1981041

• Permit No: C1981041
• IBM Index Class Name: REVISION
• Doc Date: 3/5/2008
• Doc Name: Adequacy Comments
• From: J.E. Stover & Associates, Inc
• To: DRMS
• Type & Sequence: PR4
• Media Type: D
• Archive: No

J. E. STOVER & ASSOCIATES, INC.
P.O. BOX 60340
GRAND JUNCTION, COLORADO 81506
PHONE: [phone], FAX [phone]
MINE ENGINEERING CIVIL ENGINEERING
MINE RECLAMATION CONST. MANAGEMENT
March 3, 2008 RECEIVED
MAR OS 2008
Mr. Mike Boulay Division of 1 -Lion,
Division of Reclamation, Mining and Safety Mining and Safety
101 South 3"d, Suite 301
Grand Junction, CO 81501
Re: Snowcap Coal Company, Inc.
Permit Revision (PR-4), Adequacy Response Submittal
Unit Train Loadout, Railroad Spur & Overland Conveyor
Permit No. C-1981-041
Dear Mr. Boulay:
The DRMS' letter dated September 25, 2007 transmitted its adequacy comments
regarding the referenced permit revision. Following are Snowcap's responses to the
DRMS' comments and concerns:
PR-4 PRELIMINARY ADEQUACY REVIEW COMMENTS
2.05.3(4) and 4.05.9(13) Permanent Impoundments
1. DRMS: Under the proposed plan, Sediment Pond 1 & 2 would be retained as a
permanent impoundment for the alternative postmining land use. Please include a
narrative demonstration for inclusion within an appropriate permit narrative
section or appendix, separately addressing each of the requirements in sub-
sections (a) through (f) of Rule 4.05.9(13). Please include documentation to
demonstrate compliance with applicable requirements of the Office of the State
Engineer with respect to water rights and embankment criteria.
SCC: The plans for pond retention have changed. As can be seen on Exhibit 10C, the
ponds will be backfilled. The spillways will be capped or plugged.
2.05.4(2)(b) Reclamation Plan Detailed Cost Estimate
2. DRMS: Rule-3.03.1(3)(e) requires that, for permits which include an alternative
postmining land use plan for industrial or commercial... "the Division shall require the
maintenance of bond coverage throughout the applicable liability period, sufficient for the
Division to achieve compliance with the standards for revegetation applicable to the pre-
mining land use under 4.15, in the event the alternative postmining land use is not
developed in the event of bond forfeiture". In other words, the Division retains the bond
calculated to be necessary for implementation of the original reclamation plan, so that
the original plan could be completed, if the alternative postmining land use is not
implemented. Upon approval of bond release for the Alternative Land Use portion of the