2013-07-16_REVISION - C1982056 (2)

Home Browse Search

of both surface and mineral property to include updated documents that the applicant bases his or her legal right to enter. Response: The referenced permit text section and maps have been reviewed and updated, as appropriate, to reflect current ownership. Copies of the revised pages and Map 1 accompany these responses for replacement in the PAP. 3. Technical Revision No. 67 was approved with Stipulation No. 64 attached. Stipulation No. 64 states that Twentymile Coal Company is approved to construct the Refuse Disposal Area Expansion in accordance with the designs approved in Technical Revision No. 67, Twentymile Coal Company has requested to provide bond for the increase disturbance area in three increments. The first increment, "Initial Bonded Disturbance" of 50.0 acres, is limited to construction of 30.3 acres refuse pile expansion, 2.4 acres haul road corridor, 5.9 acres unclassified stockpile, 3.5 acres topsoil stockpile, 0.4 acres stockpile haul corridors, and 7.5 acres construction of RDA 10 and RDA 11 ditches, as shown on Map C -102 (11/13/20091. Prior to disturbance of the Refuse Disposal Area expansion beyond the Initial Bonded Disturbance, Twentymile Coal Company is required to submit additional bond adequate for disturbances associated with bonding increments I and II No disturbance associated with bonding increments I and II shall occur prior to submittal and Division approval of additional bond. Please provide the Division with the status of the approved RDA expansion and the schedule of Phase II of the RDA expansion. Response: The current progress of the CRDA Expansion is shown by the updated map which accompanies these responses, to be replaced in Exhibit 26C. As indicated by this map, the current progress of the CRDA Expansion does not extend beyond the originally delineated "Phase I" area. TC, however, is poised to extend the underdrain and construct additional temporary perimeter collection ditches in conjunction with initiation of Phase II of the CRDA Expansion. This will involve an additional 30 acres of disturbance for the Phase II footprint and soil removal buffer zone. The new disturbance will be partially offset by reclamation, during the 2013 construction season, of the first two benches completed to date. It is anticipated that most, if not all of the soil and cover material from the Phase II expansion area will be direct handled for reclamation of the completed benches. TC submitted and obtained approval of TR12 -79, which reduced the bond reclamation liability by over $260,000, while keeping the same amount of bond surety (Self Bond SB -008). In addition. the updated bond reclamation cost estimate for RN06 reduces the total bond liability by approximately $57,300, and final approval is pending for a partial bond release application in the amount of approximately $347,900. Considering the reduction in reclamation liability associated with TR12 -79, RN -06, and the pending partial bond release, the amount of excess bond coverage (approximately $665,200) is greater than the calculated liabilities associated with Phase II of the CRDA expansion (estimated at approximately $197,500), so the current reclamation bond (SB -08) should be adequate to cover the projected reclamation liabilities. 4. Page 2.03 -19.1 lists the violations required by Rule 2.03.5(3). Please update the list of violations within the last 3 years. Response: The referenced text has been reviewed, and accurately reflects the information and status of any violations received during the prior three -year period (last violation was received in September 2011), so no update is necessary. 5. Pages 2.03 -36 through 37.1 identify other applicable permits required for C-1982 -056. Please provide any updates to identify current permits, revised permits, and new permits.