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COLORADO <br />Division of Reclamation, <br />Mining( and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Interoffice Memorandum <br />October 19, 2015 <br />To: Robin Reilly <br />From: Tabetha Lynch <br />RE: King II Mine (Permit No. C-1981-035) <br />TR -20, adequacy review 2A (Supplemental) Response <br />This memo is a review of the above stated response provided by GCC Energy, LLC with regards <br />to additional sampling and analysis of roof and floor materials from areas where mining is <br />currently active. My adequacy items are numbered at the end of the memo. <br />In summary, a letter was issued by the Division on 09 June 2015 with a determination that <br />additional sampling and analysis is warranted. <br />"Given the presence of the permitted Refuse Pile and Coal Mine Waste storage areas together with the <br />West Waste Bank proposed under TR 20 the Division has determined that additional sampling and <br />analysis of the roof and floor materials from the areas where mining is currently active is warranted. In <br />addition to the parameters analyzed previously our Rules also require a determination of Acid Base <br />Potential together with the various forms and fractions of Sulfur that are present Total as Sulfate as <br />Pyrite and Organic. The acid and toxic forming analysis will need to be incorporated into the TR 20 <br />review and approval process. Please submit GCC s proposed sampling methodology to the Division for <br />review prior to conducting any sampling. "(09 June 2015 Supplement to 2nd Adequacy Review) <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 />Adequacy items: <br />1. The plan provided by GCC have very few specifics or justifications relevant to the King II <br />mine. It is a copy and paste from CDRMS guidance document not a site specific plan. <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. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director <br />