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Twentymile Coal, LLC. <br />Page 2 <br />September 27, 2016 <br />3. TC requests to reduce monitoring for surface water monitoring sites for the months of August and <br />September. Please provide justification for this request using appropriate water quantity and <br />quality data. <br />4. Proposed revised page 2.04-25.1 cuts off the last paragraph on this page. Please review and <br />revise this page to insure that it follows to preceding following pages. <br />5. Please revise Exhibit 14, page 14.2 and page 14.3 to include the following NPDES permits that <br />are monitored COG -850051 and COG500054. <br />6. Please revised page 14.2 of Exhibit 14 to indicate which USGS monitoring stations the second <br />paragraph under the Surface Water, Effluent, and Spring Monitoring section is referring to. <br />These site are designated as sites 800 and 900 in the exhibit currently. <br />7. Proposed revised page 14.3 discusses monitoring of natural and spoil springs. The language of <br />this section of Exhibit 14 would indicate an annual survey is conducted for springs in May. <br />Please address the following items: <br />a. The proposed narrative for sampling of Site 7 is inconsistent with the spoil spring <br />sampling plan shown on Table A of Exhibit 14. <br />b. Please provide justification for the 35 gallon per minute sampling cut off for spring <br />monitoring. The Division is currently reviewing a technical revision for the Peabody <br />Sage Creek Mine and agreed to a qualifier that if a spring is flowing less than 1 gallon per <br />minute only field parameters will be measured otherwise the site will be sampled for <br />water quality analysis as necessary. This qualifier seems more appropriate. <br />8. In Exhibit 14 on proposed revised page 14.4 on the third paragraph the following sentences read, <br />"The EC and sulfate data will be forwarded to the Division on a quarterly basis for the period of <br />1St quarter, 2000 through 1st quarter 2001. The data willbe submitted within 45 days of the end of <br />the respective quarter." Please clarify these sentences. Has this monitoring already occurred <br />and/or is TC proposing to submit monitoring data quarterly to the Division when either site 115 <br />or 109 is discharging to demonstrate the Electrical Conductivity or Sulfate limit has not been <br />breached? <br />9. The third paragraph on page 14.4 indicates when Site 115 and 109 is discharging, additional <br />monitoring will be performed to prevent exceedances of the sulfate standard on Trout Creek <br />below Fish Creek and on Trout Creek between Middle and Fish Creek from June through <br />February. Currently Exhibit 14 requires monitoring year-round at Trout Creek below Fish Creek <br />when these sites are discharging. The proposed revised language would lead one to believe <br />monitoring will only be conducted if these sites are discharging from June through February. <br />Please revise the language to indicate yearly monitoring will be conducted at Trout Creek below <br />Fish Creek when these sites are discharging as is currently approved or provide detailed evidence <br />to indicate this requirement is no longer necessary. <br />