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Interoffice Memorandum <br />To: Janet Binns <br />From: Zach Trujillo <br />Subject: New Elk — Midterm Review <br />Date: 5/07/2012 <br />Janet— <br />Here are my comments for New Elk's Midterm Review for the following sections: <br />2.05.3 (7) —Coal Handling Structures <br />• All requirements for this rule have been met. <br />2.05.3 (8) — Coal Mine Waste and Non -Coal Processing Waste <br />• All requirements for this rule have been met. <br />• It appears page 2.05 -27i may need to be removed from the permit. Page 2.05 -27i was last revised from MR -97, <br />approved 9/30/11. TR -59, approved 10/28/11, appears to have revised this page 2.05 -27i but renamed the page <br />to 2.05 -27a. Since the page was renamed differently, page 2.05 -27i was never replaced with the most current <br />revision and left within the permit. <br />• Page 2.05 -28 refers to Figure 10 within the section but it appears Figure 10 has been removed from the permit <br />by TR -41. Please have the operator send a revised page 2.05 -28 removing its reference of Figure 10. <br />2.05.3 (9) — Return of coal mine waste to abandoned workings. <br />• All requirements for this rule have been met. <br />2.05.6 (6) — Subsidence Survey, Subsidence Monitoring, and Subsidence Control Plan <br />• All requirements for this rule have been met. <br />Additionally, after discussing with Jim Stark how the Division bonds for valley fills with respect to New Elk Mine's RDA, <br />he mentioned most refuse pits were bonded through each permit term. As approved with the current permit, New Elk <br />Mine appears to be bonded up to their current disturbance boundary just above the upland diversion ditch. If New Elk <br />plans to fill past their current disturbance boundary, they will need to post additional bond even if they have approved <br />designs at a higher elevation. Also, per Rule 4.10.2 and stated on page 2.05 -27a in New Elk's permit, New Elk should be <br />inspecting coal mine waste piles at least quarterly and submitting to the Division a certified report two weeks after each <br />inspection. <br />After reviewing New Elk's Subsidence Control, Monitoring, and Mitigation Plan and Exhibit 24, they appear to have <br />adequate subsidence monitoring survey monuments around the school and church just east of their boundary. <br />Regarding the gas well pads, as per Rule 2.05.6(6)(c)(i)(D), monitoring of established monuments and structures shall be <br />performed at least quarterly, commencing one month prior to the initiation of mining beneath any established <br />monument or structure. Also, as part of Agapito Associates, Inc.'s subsidence analysis, two survey monuments per gas <br />