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RE: Peabody Sage Creek Mining, LLC. DRMS Permit No. C-2009-087 <br />Technical Revision No. 9 (TR9), Adequacy Review No.1 <br />Dear Mr. Nettleton: <br />The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed the above referenced <br />revision submitted by Peabody Sage Creek Mining, LLC. (PSCM). The following items will need to be <br />addressed prior to the Division's approval of the revision. <br />2.05.6(3) Protection of the Hydrologic Balance <br />1. PSCM proposes to revise Table 2.04.7-T9, Summary of Groundwater Monitoring. PSCM <br />proposes to revise the frequency of when water levels will be measured from either Tri -Annually <br />and Semi -Annually to Semi -Annually or Annually without any justification. PSCM will have to <br />justify reducing the water level monitoring frequency in detail based on the Probable Hydrologic <br />Consequences found for the site, previous water monitoring data and baseline hydrologic data. <br />Please either provide this justification or change the frequency for measuring water levels back to <br />the currently approved frequency. <br />2. PSCM proposes to revise the frequency for ground water quality sampling for Wells COV2702 <br />and CW2701 from semi-annually to annually. Similar to the item above, PSCM will have to <br />justify reducing the water quality sampling frequency in detail based on the Probable Hydrologic <br />Consequences found for the site, previous water monitoring data and baseline hydrologic data. <br />Please either provide this justification or change the frequency for measuring water quality for <br />these two wells back to the currently approved frequency. <br />Under the new 2016 Technical Revision 9 section of proposed revised page 2.04-108a, please <br />revise point #3 depending on how you respond to the frequency issues cited in adequacy issues <br />No. 1 and 2 above. <br />Section 2.04.7 <br />4. Proposed revised page 2.04-106 revised the second sentence of the Surface Water Monitoring <br />section to read "SCCC proposes to maintain..." The currently approved page reads "PSCM <br />proposes to maintain..." Please revise this page to cite the correct name of the applicant (PSCM). <br />5. PSCM submitted proposed revised tables 2.04.7-T11 and T-12, the page number on the proposed <br />revised pages are both 2.04-105. These tables are currently located on page 2.04-107 and 108 <br />respectively. Please revise these pages with the correct page numbers. <br />This concludes the Division's preliminary review of TR9. The Division is required to issue a decision on <br />the application by October 14, 2016. All of the adequacy review items will need to be addressed to the <br />satisfaction of the Division prior to the approval of the TR. If you need additional time to address the <br />Division's concerns, please request an extension of the decision date. <br />If you have any questions feel free to contact me at (303) 866-3567, extension 8120. <br />