2013-08-13_REVISION - C1982056

• Permit No: C1982056
• IBM Index Class Name: Revision
• Doc Date: 8/13/2013
• Doc Name: Adequacy Response Review
• From: DRMS
• To: Twentymile Coal Company
• Type & Sequence: RN6
• Email Name: JDM
• Email Name: DIH
• Media Type: D
• Archive: No

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Kennard Perry, and William Rogers are no longer current. Please update the
referenced surface owner contact information to reflect current information.
3. Division Initial Comment: 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 70.5 acres construction of RDA 10 and RDA 11
ditches, as shown on Map C -102 (11/13/2009/. 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 IL 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.
TC 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 P' area. TC, however, is poised to extend the underdrain and
construct additional temporary perimeter collection ditches in conjunction with imitation
of Phase II of the CRDA Expansion. This will involve as 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 11 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
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.
Division Response: The Division has recalculated the Reclamation Cost Estimate to
include the Phase II portion of the Refuse Disposal Area Expansion. These costs have
been added to Tasks 134, 146, and 185. These costs reflect the 30 additional disturbed