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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />14 November 2014 <br />Tom Bird, Manager of Coal Services <br />GCC Energy, LLC <br />6473 County Road 120 <br />Hesperus, CO 81326 -9633 <br />Re: King Coal Mine (Permit No. C- 1981 -035) <br />Technical Revision No. 20 (TR -20) — Use of Coal Mine Waste as Highwall Backfill <br />Second Adequacy Review <br />Dear Mr. Bird: <br />The Division has reviewed GCC Energy, LLC's (GCC's) response to its November 27, 2013 preliminary <br />adequacy review of the TR -20 application. The response package was received on October 6, 2014, and <br />included the following items (King I permit volume): <br />• Table of Contents pages ii and iii <br />• Section 2.05.3 pages 2, 3, and 4 <br />• Section 2.05.4 pages 4, 5, and 5a <br />• Appendix 10(4) Revised Geotechnical Engineering Study by Trautner Geotech (Sep. 30, 2014) <br />• Map King 1 -007 Operation Plan & Surface Features <br />• Map King 1 -011 Final Contour <br />• Map King 1 -016 West Waste Bank Design <br />• Map King 1 -016A West Waste Bank Design <br />The Division's initial adequacy comments are repeated below, updated in bold italics to reflect their <br />current status. <br />Section 2.05.3 Operation Plan — Permit Area <br />1. Subsection: "Mine Bench" <br />a) The 4t" paragraph refers to a "back- filled gully'. Is this intended to mean the drainage <br />occupied by the permitted Refuse Pile? Please clarify the text. <br />The text was revised as requested. This item is resolved. <br />2. Subsection: "Mine Waste Rock Disposal" <br />a) Throughout this section, the term "storage area" has been used to describe the areas where <br />permanent disposal of coal mine waste will occur. Please revise this section to differentiate <br />clearly between these three features: 1) the permitted valley -fill Coal Mine Waste Disposal <br />Area ( "Refuse Pile "); 2) the proposed "West Waste Bank" Coal Mine Waste Disposal Area; <br />o -cod <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http: / /mining.state.co.us <br />John W. Hickentooper, Governor 1 Mike King, Executive Director 1 Virginia Brannon, Director <br />