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NECC Response: <br />Permit text narrative has been modified to identify the three development waste <br />piles as DWP (the original and now reclaimed pile west of the main gate), <br />DWDA #2 (the pile immediately east of the main gate), and DWDA #3 (the <br />recently approved but yet to be constructed pile at the West Mine). Text changes <br />have been made throughout section 2.05, as necessary, to ensure that no <br />ambiguity exists regarding the naming convention and reference to these three <br />approved development waste piles at the site. <br />26(a). Accurate topsoil balance information. <br />NECC Response: <br />Permit text narrative has been added to revised page 35 of section 2.05 to rectify <br />acres required to receive topsoil and document the volume of topsoil currently <br />stockpiled at the site. <br />26(b) Location of topsoil piles shown on a map. <br />NECC Response: <br />NECC believes all topsoil piles are shown on a map. NECC believes the topsoil <br />pile in question is the topsoil borrow area. This location is clearly indicated on <br />Map 16 for the West Mine. <br />26(c) Topsoil and subsoil volumes. <br />NECC Response: <br />The vast majority of the facility area was disturbed pre -law and as such, topsoil <br />was not harvested and/or stockpiled. One significant exception to this is the RDA <br />located north of Highway 12. Previous permitting committed to topsoil areas <br />based on the presence or absence of "refuse" type material present on the existing <br />disturbed area. Approved Table 24 was developed to estimate topsoil volumes <br />potentially available as the RDA grows to its full design capacity. NECC believes <br />that this information remains valid and has adjusted the dates in the table <br />accordingly. NECC believes it is appropriate to use the "worst- case" disturbance <br />scenario for the purposes of calculating reclamation costs for the RDA. Based on <br />currently approved permitting for the RDA and the current verified size of the un- <br />reclaimed RDA surface of 19 acres, NECC believes that a conservation value of <br />23 acres of "worst- case" exposure at the RDA is appropriate. The "worst- case" <br />assumption for RCE purposes is consistent with the assumptions used by the <br />Division at other mine sites where contemporaneous reclamation occurs at mining <br />pits and refuse disposal piles. While topsoil originally harvested from RDA <br />operations is now slated for use on the facility areas where topsoil was not <br />harvested, NECC believes it is appropriate and reasonable to consider those <br />12303 Airport Way Ste 200 - Broomfield CO 80021 • Phone: 303.327.1525 - kent @gorhamenergyconsultants.com 8 <br />