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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 />March 10, 2016 <br />From: Leigh Simmons <br />To: Rob Zuber 0J, <br />Subject: Colowyo Mine (Permit No. C-1981-019) <br />PR -4, groundwater review. <br />Review of response to initial adequacy review. <br />Colowyo Coal Company (CCC) responded to the initial adequacy review of the PR -4 application <br />with letters dated November 20, 2015; and December 17, 2015. Below are my comments on <br />those responses, numbered in accordance with the initial adequacy review letter. <br />Preamble <br />In this adequacy review four items are addressed with proposed stipulations (items 80, <br />c; 81, a; 81, b; and 86). This is an attempt to expedite the permitting of PR -04 whilst <br />ensuring that all regulatory requirements are satisfied. Depending on their schedule, it <br />may be possible for CCC to address some of these issues before the Division proposes a <br />decision which would render the relevant stipulations redundant. <br />Rule 2.04.5 — General Description of Hydrology and Geology <br />64. In Volume 1, on p2.04.5-1, "general area" is defined, in accordance with rule 1.04, as "that <br />topographic basin that surrounds the area to be mined during the life of the operation". <br />In paragraph 5 this definition is contradicted: "Additional drainages in the "general area', but <br />outside of the topographic basin..." Similarly confusing language is found in Volume 12 (Rule 2, <br />Page 9) and Volume 15 (Rule 2, Page 11). The Division recognizes that this is legacy text and is <br />not proposed to be revised with PR -04, but holds that it should be clarified. <br />Please amend the language in section 2.04.5 in Volumes 1, 12 and 15 so that the use of "general <br />area" is consistent with its definition. <br />CCC revised section 2.04.5 in Volumes 1 and 15 satisfactorily; however the text in Volume 12 <br />appears not to have been updated. Please amend the language in section 2.04.5 in Volume 12 <br />so that the use of "general area" is consistent with its definition. <br />The response is sufficient. <br />Rule 2.04.6 — Geology Description <br />65. In Volume 15, Rule 2, Page 12, stratigraphic cross sections are referred to (Figures 2.04.6-5A <br />through —H). The text states that the key to the location of these cross sections is given on Map <br />QF GQ�Q <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 * 1876 <br />