2010-06-10_REVISION - C1980007 ‎(3)‎

• Permit No: C1980007
• IBM Index Class Name: REVISION
• Doc Date: 6/10/2010
• Doc Name: Preliminary Adequacy Review
• From: DRMS
• To: Mountain Coal Company
• Type & Sequence: TR121
• Email Name: TAK
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203 C O L O RA D O
D I V I S I O N O F
Phone: [phone] RECLAMATION
FAX: [phone] MINING
June 10, 2010 I SAFETY
Kathleen G. Welt Bill Ritter, Jr.
Mountain Coal Company, LLC Governor
P.O. Box 591 James B. Martin
Somerset, CO 81434 Executive Director
Loretta E. Pineda
Director
Re: West Elk Mine (Permit No. C-1980-007)
Technical Revision No. 121 (TR- 121)
Methane Drainage Wells E3-71,75, 76, 78, and E4-76, 81, 82, 83
Preliminary Adequacy Review
Dear Ms. Welt:
DRMS has completed a preliminary adequacy review of the above-referenced submittal and has the
following comments.
1) DRMS has forwarded to the State Historic Preservation Officer (SHPO) the cultural and
historic resources information submitted in the TR-121 application. DRMS is waiting for
verification from the SHPO that the proposed work will not adversely affect a place that is
listed on or is eligible for listing on the National Register of Historic Places. This verification
from the SHPO is required by Rule 2.07.6(2)(e)(i). The Division's incompleteness letter of
April 30, 2010 explains why SHPO clearances for past revisions may not apply to a portion
of the work proposed in TR-121.
2) DRMS has forwarded to the Office of Surface Mining (OSM) the fish and wildlife
information submitted in the TR-121 application. DRMS is waiting for a response from the
OSM before making the finding required by Rule 2.07.6(2)(2)(n) regarding adverse impacts
to endangered or threatened species and their habitats, and before determining the fish and
wildlife plan is adequate as required by Rule 2.07.6(1). The Division's incompleteness letter
of April 30, 2010 explains why fish and wildlife clearances for past revisions may not apply
to a portion of the work proposed in TR-121.
3) DRMS is waiting for verification from the U.S. Forest Service of surface right-of-entry pursuant
to their letter of May 24, 2010.
4) DRMS is preparing a reclamation cost estimate for TR-121 in which it will be necessary to
determine the incremental bond amounts for recently drilled MDWs and apply those amounts
to the current reclamation liability. Please submit a revised copy of the map titled "E Seam
MDW Drilling Plan" that shows current MDW information. The copy of this map in the
TR-121 submittal does not show all of the MDWs in panels E-1 and E-2. The previously
approved copies of this map in the permit application (in Exhibit 80, Tabs TR-111 and PR-
14) do not show current locations and well numbers for all of the E-Seam MDWs that have
been drilled.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines