2011-10-24_REVISION - C1981044 - Laserfiche WebLink

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g. A request for the retention of any permanent structures, roads, ponds or railroad tracks bridges: Please include the appropriate landowner and government agency approval letters and /or permits, cis necessary. It. A detailed plan for the permanent sealing of the Mine No. 5A portals.. i. A detailed plan for the sealing ofall wells and drilled holes. This should include a list of which holes will be sealed and which holes will remain open for monitoring purposes A detailed baekfrlling and grading plan including pr ernining and postmining topography and cross- sections and accurate backfilling volumetrics. k A detailed topsoil replacement plan that includes a snap that shows all of the current topsoil stockpiles and where the topsoil will be spread fcrr f vial reclamation. Response: Please refer to our previous response to Comment 1. We submit that MCM has acted in good faith to maintain the Williams Fork Mines site and remaining facilities in good condition, and has met our permit obligations. Given that a reasonable potential exists for future reactivation and operation of the Mine, a commitment to Permanent Cessation and fiill site reclamation at this time would not be reasonable or responsible. The stated purpose and intent of the applicable regulators provisions are protection of the environment from the potential adverse effects of mining. With our ongoing monitoring and maintenance of the site, no adverse effects to the environment have been identified, or would be anticipated. In reviewing the referenced Reclamation Plan text, we recognize (as von have indicated) that reclamation details for some facilities may be lacking, and would be open to working with the CDRMS to develop additional details in specific areas. 13. Permit page 2. o5- 23contains a section on "Removal of Structures and Facilities ". This section contains a general description of the reclamation activities that will take place at the site. In 2008, 2009 and 2010 MCM completed a number of reclamation activities including the demolition of structures and the final reclamation of the No. 9 Mine refuse pile. Please update the "Removal of Structures and Facilities" section on permit page 2.05 -23 to include a discussion of the reclamation activities that were completed in 2008, 2009 and 2010. Response: The Permit discussion of structure and facility removal has been reviewed and updated as appropriate, to reflect recent site demolition and reclamation activities. Copies of the revised Permit discussion accompany these responses for replacement in the PAP. 14. Permit page 2.05 -2=1 includes a section onBackfilling and Grading that references Map 29, which shows the areas to be backfilled and graded, and Table 63, which gives backfill volumes. Bused on the recent reclamation at the site and the anticipated future reclamation, please review Map 29 and Table 63 and update them accordingly. This updating should be done in conjunction with the creation of the detailed reclamation plan requested in question 12 above. Response: The referenced Permit backfilling and grading nap and table have been reviewed, revised, and updated, as appropriate, to reflect recent site reclamation activities. Copies of the revised map and table accompany these responses for replacement in the PAP. 1.5. Permit page 2.05 -25 contains a short section titled "Reclamation Timetable" that references Table 67. Table 67 is a chart that shows approximately how long each phase of reclamation will take (for example, the removal of facilities at the No. 5 Mine will take 90 days). As stated in question 12 above; the Division is requesting a more detailed timetable that includes actual dates for reclamation. Please update Table 67 and submit it with the revised reclamation plan and timing requested in question 12 above. 5