2016-10-25_REVISION - C2009087 (2)

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V. COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 October 25, 2016 Miranda Blomquist Peabody Sage Creek Mining, LLC. 29515 Routt County Road 27 Oak Creek, CO 80467 RE: Peabody Sage Creek Mining, LLC. DRMS Permit No. C-2009-087 Technical Revision No. 9 (TR9), Adequacy Review No. 3 Dear Ms. Blomquist: The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed your response to the Division's second adequacy review for the above referenced revision. The items below are number to correspond to the adequacy review items cited on the Division's second adequacy review letter. If the original adequacy review item has been addressed it will be noted as such. If additional information or revisions are needed, that will be discussed. 2.05.6(3) Protection of the Hydrologic Balance 1. Item No. 1, PSCM provided some discussion and justification for the reduction in frequency for monitoring ground water levels while the mine remains inactive. The adequacy review response cover letter indicated that it is PSCMs intention to revert back to the original (2015) monitoring plan once mining resumes. However, this intention is not made clear in the proposed revised permit text. Given this, the Division believes it would be appropriate to have a copy of the currently approved monitoring plan in the permit with a commitment made to reinitiate this plan when mining resumes. Instead of replacing the currently approved Table 2.04.7-T9 with the proposed alternative monitoring plan, please keep the currently approved monitoring plan in the permit and indicate that this monitoring plan will be initiated when the mine is active. The proposed alternative monitoring plan can then be put into the permit as an additional table (Table 2.04.7-T9A for example) with some type of notation that this monitoring plan will be implemented while the mine is currently idle. a. PSCM Response: PSCM has made edits to the PAP, Section 2.04.7 Hydrologic Description. These changes reflect different monitoring programs for active and inactive/idle mining statuses. PSCM has updated pages 2.04-103, 104 and 2.05-93 and are included in this submittal as an attachment. b. DRMS Response: Proposed revised page 2.04-104 contains two tables as requested, thank you. However, table 2.04.7-T9 (active mining groundwater monitoring plan) does not reflect the plan currently in place. Currently, water levels are measured either Tri - annually or Semi -Annually. Wells COV2702 and COV2701 are measured for water fly.. C H 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining. state. co. us I John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director * r 1876s*