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Memo <br />To: Jason MusicMsponse-Rvicw From: Janet Binns <br />Date: May 14, 201 <br />Re: Adequacy R Foi el Creek Mine Permit Renewal No. 5 <br />I have reviewed Twentymire Coal LLC's (TCC) responses to the Division's adequacy letter dated January <br />16, 2009. The Division received TCC's response on April 21, 2010. Due to the length of time that had <br />passed since the Division had reviewed the Foidel Creek Mine's Reclamation Cost Estimate (RCE), <br />reclamation costs were updated to reflect current industry costs, and to include approved revisions to the <br />permit that have occurred since the January 2009 adequacy letter. The Division's estimate is included <br />with this memo. <br />I have responded to the adequacy items that we discussed. I kept the original numbering and question <br />from the Division's initial adequacy letter. <br />1) The Division was unable to find in TCC's Reclamation Cost Estimate (RCE) Appendix A costs to cover <br />the total acreage of the Refuse Disposal Area (RDA). The cost for covering 15 acres of disturbance is <br />included, Appendix. A page 54. However, the acreage of the entire RDA is approximately 58 acres. <br />TCC needs to provide reclamation cost estimates for covering the entire RDA. <br />Roundabout TCC answered that they have included the cost to cover & topsoil the "old" RDA in page <br />1-If of TCC's estimate quick accounting of the volumes and cost associated with covering the entire <br />"old" RDA, finds that this task has indeed been accounted for. This question illustrates the problem <br />with inconsistencies is naming designations. If the PAP and permit maps refer to the coal waste pile <br />as the Refuse Disposal Area, or RDA, but the operator's reclamation cost estimate references tasks <br />associated with the waste rock area, the Division does not assume that these two differently named <br />areas are indeed, the same thing. TCC's response that,TCC's Appendix A pages 1 through 1 f are <br />applicable to the "old" RDA reclamation is acceptable to the Division. The Division has updated <br />reclamation costs to reflect 2010 costs. <br />2) It is unclear from the PAP where the balance of RDA cover material will be transported from. <br />Approximately 70, 000 cubic yards. of clay material are accounted for on the west side of the RDA <br />(relocated to a permanent excess spoil pile with the approval of MR233). 70, 000 cubic yards of <br />material is adequate to cover only 15 acres of the RDA. The RDA is approximately 58 acres. Please <br />provide the Division with a cover material balance for the RDA. Please include haul distances for <br />transporting the material to the RDA. Please provide this information for the currently approved mine <br />plan. (Rule 4.10.4(5)). <br />TCC provided an explanation of the volumes available and where to volumes are located. A quick <br />mass balance indicates that TCC proposed volume will be acceptable to cover the RDA + CRDA <br />expansion with the required 4 ft. of cover. This response resolves my concern. <br />6 Section 2.05, p. 105.1 includes a discussion of reclamation of the NMD site; dismantling of the surface <br />facilities, removal ofpowerline, transformers, structure, regrading the pad and road, but there is no