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question). Oxbow's response does not address all the required information listed in Rule <br />2.05.4(2) for a comprehensive reclamation plan of the Elk Creek riparian; however, the <br />Division does recognize, that significant changes to the reclamation plan are beyond the <br />scope of the permit renewal process. At a future date before reclamation, a technical <br />revision will need to be submitted which addresses the Elk Creek riparian reclamation. <br />Oxbow Response: Oxbow did not propose, nor do we believe a comprehensive reclamation plan <br />is necessary, for the presently approved reclamation plan of areas associated with Elk Creek <br />Reclamation. We merely proposed the planting of additional shrub and tree species to enhance <br />the reclamation of areas located along the future reclaimed Elk Creek drainage to take advantage <br />of anticipated increased levels of soil moisture near the creek. <br />Exhibits and Drawings - Comment 1. -- Map 2.04 -M5 — Ground Water Hydrology was <br />submitted with nine (9) additional ground water monitoring wells labeled on the map (TC- <br />1, TC -2, WSC -DH12, SC -2, P -1, EC -16, EC -5, EC -6 and EC -7). These wells are not in the <br />permit monitoring plan and were not reported in the 2012 AHR. Please clarify if these <br />wells need to be included on the map or in the monitoring plan. Ground water well BC -1 is <br />located on Map2.04 -M5 east of Hawk's Nest Creek. The Hydrologic Monitoring Plan - <br />Exhibit 2.05 -E7, page 1 shows that it is on Bear Creek. Please clarify the location of well <br />BC -1 and make the map and text consistent. <br />Oxbow Response: Oxbow did not provide a map showing additional ground water monitoring <br />wells. The presently approved map was merely modified, as requested, to revise the Permit <br />Boundary. We presume that when this map was originally submitted with PR -04 in the year 2000 <br />that there was some desire by reviewers to show references to these historic well sites. We <br />suggest the map serves some historical reference purpose should a question arise concerning <br />these old sites. The additional sites are not in the monitoring plan. The monitoring plan presented <br />in the 2012 AHR is correct. <br />However, the reference to BC -1 is incorrect and a corrected Map 2.04 -M5 is included herein. <br />Exhibits and Drawings - Comment 6 -- Oxbow submitted a new typical design for drainage <br />and sediment control of degasification wells that does not include a clean water diversion <br />ditch. Drawing 2.05 -M4 (4/4) shows a typical plan for drainage and sediment control of <br />degasification wells with a clean water diversion ditch. It is not clear from the text or <br />drawings the conditions that determine when each typical plan is to be implemented. <br />Please clarify when each typical plan is to be implemented. Also, the new drawing (without <br />a clean water diversion ditch) does not have a page number for insertion into the permit. <br />Oxbow Response: As we noted in the August 13, 2013 RN -06 response letter, the most recent <br />Typical GVB design was prepared for TR -67 in 2010 and slightly modified for RN -06 by <br />removal of the little used clean water diversion. The diversions were historically used <br />sporadically with the Sanborn Creek Mine methane drainage program. Because the utility of <br />these diversions were later judged to be limited at the Elk Creek Mine they have been little used <br />and showing them on the typical design seemed extraneous. The RN -06 typical design version is <br />now relevant and we do not propose to build such diversions going forward on future sites. The <br />diagram may be placed in Section 9 of Exhibit 2.05 -E3. <br />• Page 2 <br />