2011-07-07_REVISION - C1981022 - Laserfiche WebLink

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SECTION III — STATUS OF STIPULATIONS Since the submittal of the original permit application there have been a total of thirty -four stipulations issued. All of these stipulations have been terminated or complied with. No additional stipulations were placed on the permit since the permit renewal issuance date of May 28, 2009 for RN -05. According to the Division's records in the permitting database, there is one outstanding commitment attached to Permit No. C- 1981 -022 listed below. Commitment 1 - Somerset Mining Company will address inundation of Sanborn East workings by water in possibly flooded Hawk's Nest workings entering through borehole No. 8. See page 2.05 -391V B of the Somerset Permit. Issued September 25, 1992. Commitment 1 remains from the Somerset Mine and the due date for the commitment was 4111193. Commitment 1 is no longer valid and will be terminated as of the date of this Midterm Review for the reasons described below. According to OMLLC all but one borehole associated with the Hawk's Nest Mine was permanently sealed. The reclamation work and borehole sealing was done by the Division following forfeiture of the bond by the operator of the Hawk's Nest Mine. One borehole remains at the former Hawk's Nest Mine at a down -dip location completed to the E -Seam which does not extend into the Sanborn Creek mine in question. This borehole is still venting methane and according to OMLLC personnel a decision was made to leave the borehole open. Further, the Sanborn East workings have been entirely sealed off and the official closure date for the Sanborn Creek Mine is June 6, 2003. Therefore, Commitment 1 is no longer valid to the Sanborn Creek and Elk Creek Mine permit application package (PAP). There are no active stipulations or commitments placed on the permit at this time. SECTION IV — MIDTERM ADEQUACY QUESTIONS The Division has the following adequacy comments regarding this Midterm Review. 1. During recent inspections, Mr. Jim Kiger, Environmental Manager for Sanborn Creek and Elk Creek Mines has indicated that there has been a newly implemented corporate structure for OMLLC. As such the ownership and control and identification of interests information will need to be updated. Please update Section 2.03 of the PAP, accordingly. This will require a revision to the PAP. 2. As described below in Section VI Bonding Summary, the Division recalculated the reclamation cost estimate for the Sanborn Creek and Elk Creek Mine in conjunction with the 2011 Midterm Review. The new reclamation liability at the Elk Creek Mine, based on the 2011 Midterm Review and Minor Revision 96, which was approved following the calculation of the 2011 Midterm Review estimate, is $4,253,709.00. The previous liability at the Elk Creek Mine was $4,767,306.00. The decrease in reclamation liability for the Midterm Review, of $513,597.00, is mainly due to a change in the mine's borehole sealing plan, approved with Technical Revision 66 on 12 March 2010. OMLLC Sanborn Creek and Elk Creek Mine -6- July 7, 2011