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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />09 June 2015 <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 />Supplement to 2nd Adequacy Review <br />Dear Mr. Bird: <br />The Division issued a second adequacy review for TR -20 on November 14, 2014, and we understand that GCC <br />Energy, LLC (GCC) is working with a consultant to prepare a response to the remaining adequacy concerns. <br />We recently reviewed the information presently available in the King Coal Permit regarding acid-forming and toxic - <br />forming materials. Analyses of coal, roof, and floor strata are discussed in Section 2.04.6 (Geology) and Appendix 4 <br />of the King I and King II permit binders. We found that the number of samples that were analyzed is relatively <br />small, and that the data reveals significant variability. <br />Given the presence of the permitted Refuse Pile and Coal Mine Waste storage areas, together with the West <br />Waste Bank proposed under TR -20, the Division has determined that additional sampling and analysis of the roof <br />and floor materials, from the areas where mining is currently active, is warranted. In addition to the parameters <br />analyzed previously, our Rules also require a determination of Acid -Base Potential, together with the various forms <br />and fractions of Sulfur that are present (Total, as Sulfate, as Pyrite, and Organic). The acid- and toxic -forming <br />analysis will need to be incorporated into the TR -20 review and approval process. Please submit GCC's proposed <br />sampling methodology to the Division for review prior to conducting any sampling. The plan should be <br />submitted by June 30, 2015. <br />Rules that are or may be permanent to this issue are as follows: <br />➢ 1.04 Definitions: (1a), (2), (139), and (140) <br />➢ 2.04.6(3)(a) Geology Description — Underground Mining: (iii)(C)&(D); (iv)(D); and (v)(B) <br />➢ 4.05.1(4) Hydrologic Balance - General: (b)(vii) and (c)(iii) <br />➢ 4.05.8 Hydrologic Balance - Acid-forming and Toxic -forming Spoil <br />➢ 4.05.11 Ground Water Protection <br />➢ 4.14.1 Backfilling and Grading—General: (2)(f)(iv) <br />➢ 4.14.3 Backfilling and Grading — Covering Coal and Acid- and Toxic -Forming Materials <br />You are welcome to contact me with any questions you may have. <br />Best regards, <br />I all <br />Marcia L. Talvitie, P.E. <br />Environmental Protection Specialist <br />Cc: Dan Hernandez, DRMS <br />Christine Belka, OSMRE <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 I y " o <br />John W. Hickentooper, Governor I Mike King, Executive Director I Virginia Brannon, Director * * <br />'� f876 <br />