2016-10-27_REVISION - C2009087 (5)

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Peabody Sage Creek Mining, LLC Peabody Sage Creek Mine 29515 Routt County Road 27 I Oak Creek, CO 80467 I 970-870-2700 October 26, 2016 Jared Ebert Colorado Division of Reclamation, Mining, & Safety 1313 Sherman St., Room 215 Denver, CO 80203 RE: Peabody Sage Creek Mining, LLC. DRMS Permit No. C-2009-087 Technical Revision No. 9 (TR9), Adequacy Review No. 3 PSCM Response Dear Mr. Ebert: PSCM has reviewed your Adequacy Review No.3 dated October 25, 2016. PSCM has addressed the items of interest in this letter. Please review the following information addressing these items: 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 quality parameters Semi-Annually not annually. Please update this table to reflect the currently approved monitoring schedule. c. PSCM Response: PSCM has revised Table 2.04.7-T9 to reflect the monitoring program currently in place. An updated page 2.04-104 has been included in this submittal as an attachment.