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U <br />Mr. Zach Trujillo <br />January 27, 2016 <br />Page 2 <br />a. Please revise table 2.04.6-5 to better reflect the content of the Wyoming DEQ reference cited. <br />Response: Wyoming DEQ guidelines are not necessarily applicable in the State of Colorado and were <br />included in the permit application package (PAP) by the previous owner of the Colowyo Mine. Tri-State <br />as the current owner and Colowyo believe that the Colorado Guidelines for the Collection of Baseline <br />Water Quality and Overburden Geochemistry Data are sufficient to characterize the overburden quality in <br />the Collom Pit. Therefore, all references to Wyoming DEQ guidelines, included on, but not limited to, <br />Tables 2.04.6-5, 2.04.6-6, and 2.04.6-7 have been removed for the PAP. Wyoming DEQ guidelines <br />citations contained in Exhibit 6, Item 9 have also been removed. <br />b. Please present additional data that will allow more adequate characterization of the overburden <br />material in the Collom pit; pursuant to rule 2.04.6(2)(b)(h) the Division suggests an initial spacing of <br />one hole per 80 acres. <br />Response: Please see response to Item 70(a) also. The Colorado Mined Land Reclamation Division, <br />Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data, provide a <br />suggested drill hole spacing of one hole per square mile, and a minimum of three drill holes that should be <br />sampled. For the Collom expansion area, drill hole data has been provided for 6 drill holes as shown on <br />Map 1113 and discussed in Volume 15, Rule 2, Page 16. The drill hole locations provided meets the one <br />hole per square mile requirement within the permit area, and exceeds the minimum requirement of three <br />drill holes. <br />In addition, geologic conditions that will be encountered in the Collom Pit are not any different than those <br />found at the existing operations. Colowyo has overburden quality data from the existing operation that <br />indicates the overall overburden quality at the Colowyo mine is relatively benign. Please refer to the <br />2015 Annual Reclamation Report (Section 8). <br />Finally, under the PR -03 application the Division approved the drill hole locations and data provided, <br />which indicates to Colowyo that the overburden characterization at the Collom Mine is adequate as <br />agreed upon by the Division when it issued an approval on PR -03. Please refer to Section B.III.E in the <br />Division's "Proposed Decision and Findings of Compliance for the Colowyo Coal Mine C-1981-019 <br />Permit Revision No. 3", dated April 10, 2013. Colowyo is not proposing any changes under PR -04 to the <br />Collom Pit that would make the existing, approved drill hole locations and subsequent data set invalid or <br />not comprehensive enough for the Division. Therefore, no additional drill hole locations have been <br />proposed as what is already contained in the PAP has been reviewed and approved by the Division. <br />Colowyo has, in lieu of this comment, updated Section 2.04.6, Evaluating Geochemical Properties of <br />Overburden to better reflect usage of the Guidelines for the Collection of Baseline Water Quality and <br />Overburden Geochemistry for the drill hole locations. Also, Section 2.04.6, Exploration Test Boring <br />Results Summary has also been updated to provide a better analysis of the overburden characterization for <br />the Collom Pit. <br />c. Please revise Exhibit 6, Item 9; Tables 2.04.6-6 and -7; and the text of Volume 15, Rule 2, Pages 15- <br />18 accordingly. <br />AN EOUAL OPPORTUNITY/AFFIRiVA.TIVE AC77ON EMPLOYER <br />A Touchstone Energy' Cooperative <br />