2015-11-23_GENERAL DOCUMENTS - C1982056

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constituents and update the Probable Hydrologic Consequences section of the permit and assess the negative impacts of these elevated constituent levels. 2.05.6(6) Subsidence Survey, Subsidence Monitorinz, and Subsidence Control 55. Please depict and label the powerlines that exist within the permit area on Map 23b. 56. Section 2.05.6(6)(c) of the permit discusses the subsidence monitoring program for the Foidel Creek Mine. Since the last permit renewal (RN -06), it appears mining and subsequent subsidence has occurred in the Western Mining District. Pages 2.05-191.6 to 191.8 discuss the monitoring requirements that pertain to the areas mined/subsided since the approval of RN -06. Page 2.05- 191.8 indicates that subsidence reports will be submitted to CDRMS semi-annually, 60 days after the end of the period. The format of the report is included in Exhibit 34. The last subsidence monitoring report submitted to the Division was received on July 18, 2007. Based on the review of the subsidence monitoring program and approved mining sequence, it appears subsidence monitoring should have been conducted and semi-annual reports submitted since the approval of the RN -06 application. Was monitoring conducted for the structures and renewable resources lands in accordance with the plan discussed on in section 2.05.6(6)(c) of the permit? If so, please submit a report in accordance with the format approved in Exhibit 34 with the results of the monitoring. 57. Page 2.05-191.7 indicates hydrologic monitoring of surface and alluvial wells sites will be conducted along Fish Creek to assess the subsidence impacts resulting from mining in the WMD. This page indicates that results of relevant ongoing hydrologic monitoring will be incorporated into the semi-annual subsidence reports. Please review the results of the relevant hydrologic monitoring data and provide an assessment of the mining impacts on the Fish Creek AVF and include it in the subsidence report discussed in the item above. 3.02.4(2)(e)(i)(D) Performance Bond 58. On October 30, 2015, the Division sent Mr. James A Tichener of Peabody Investment Corporation a letter. The letter indicated that it had come to the Division's attention that it had not received the required quarterly financial statements for 03/31/15, 06/30/15, and 09/30/15 pursuant to the above cited rule. The letter requested this information to be submitted by November 20, 2015. At the writing of this letter the Division has not received this information. Please submit this information. 4.05.13(1) Groundwater Monitoring Foidel Creek Mines' groundwater points of compliance are as follows: 97013TM (Twentymile Sandstone), 008-77-58 (Wadge overburden), 008-AU3 (Fish Creek alluvium), 008 -AT -1 (Trout Creek alluvium), and 008 -AV -2 (Foidel Creek alluvium). Please address the following issues: 59. It is not stated in the monitoring plan to what numeric standard the point of compliance wells are required to meet. Table 9 Summary of Groundwater Rights shows Domestic use wells within the POC monitored intervals. The Hydrologic Monitoring Plan needs to be updated to include the required numeric standard for the Point of Compliance well Analysis Parameters. It is currently not clear if the required numeric standard are to be meeting Domestic or Agricultural standards. 60. Have the proposed wells WC008A and WC013A been installed (monitoring program exhibit 14A)? They are shown on Map 13A, but have not been acknowledged as current monitoring wells in the monitoring plan. 61. The 2014 AHR references potentiometric surfaces within the written interpretation of the data and they are referenced within the permit related impacts to the hydrologic balance; however, Foidel Creek Mine -13- 11/23/2015