Laserfiche WebLink
Page 11 of 12 <br />drainage of the Trout Creek Sandstone associated with mining. The referenced text has <br />been reviewed and updated, as appropriate, to reflect the results of ongoing monitoring. <br />Copies of the revised text pages accompany these responses for replacement in the PAP. <br />Division Response: This response is adequate. <br />20. Division Initial Comment: Exhibit 14 pages 14 -1 and 14 -2 identify current NPDES <br />permits. Please revise these pages to remove any terminated NPDES permits and include <br />any new NPDES permits. <br />TC Response: The referenced text pages have been reviewed and revised, as appropriate, <br />to identify the current, active, CDPS permits. Copies of the revised pages accompany <br />these responses for replacement in the PAP. <br />Division Response: This response is adequate. <br />21. Division Initial Comment: Abandoned wells FBR -1113, FO -1, FO -2 and deactivated <br />wells 91M005 and TC008- 75 -EFC were not located on approved Map 13A. Please <br />revise Map 13A to include the location of all wells active, deactivated, or abandoned. <br />TC Response: The referenced map has been reviewed, revised, and updated, as <br />appropriate, to show the location of all wells. Copies of the revised map accompany <br />these responses for replacement in the PAP. <br />Division Response: This response is adequate. <br />22. Division initial Comment: The Division is currently updating the reclamation cost <br />estimate for the 2013 Foidel Creek Mine Permit Renewal, RN -6. The Division is <br />updating the reclamation cost estimate with costs that were revised and updated in 2012. <br />This updated estimate will be provided to Twentymile Coal upon completion and may be <br />revised based on adequacy responses provided by Twentymile Coal. The estimate <br />includes reclamation tasks identified in the permit that were updated with revision to the <br />permit since the 2010 Midterm Review Cost Estimate. <br />TC Response: TC has reviewed the updated reclamation cost estimate, and the only <br />issues of significant concern are the increase of roughly 23 percent in job superintendent <br />hours, and the increase in "Reclamation Management and Administration" to 5 percent. <br />No rationale is provided for these increases and they represent a significant increase in <br />total job cost. <br />Division Response: The Division has addressed the Draft Reclamation Cost Estimate <br />associated with RN -6. Due to the addition of the disturbance associated with Phase II of <br />the RDA Expansion, Tasks 134, 146, and 185 have been revised. In addition, two tasks <br />were identified as tasks entered twice (Tasks 072 and 152) and these tasks were removed. <br />