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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 />November 29, 2016 <br />Jerry Nettleton <br />Twentymile Coal, LLC. <br />29515 Routt County Road 27 <br />Oak Creek, CO 80467 <br />RE: Foidel Creek Mne; C-1982-056; Technical Revision No. 86 (TR86) <br />Adequacy ReviewNo. 2 <br />Dear Mr. Nettleton: <br />The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed the above referenced <br />technical revision adequacy review response letter and material submitted. The following is a list of the <br />adequacy review items from the Division's November 15, 2016 preliminary adequacy review letter <br />followed by the response provided by Twentymile Coal, LLC (TC). If additional information or revision <br />is required it will be noted. If an item is resolved, that will be indicated. <br />2.05 — Operations and Reclamation Plan <br />Based on TC's response letter to the Division's completeness review, the variance originally <br />requested to disturb areas within the stream buffer zone may no longer be necessary because TC <br />has selected another tie-in location north of Haul Road C outside of the stream buffer zone. <br />However, the letter alludes that there may be disturbance within the stream buffer zone but it will <br />be within the disturbed areas of Haul Road C. Based on Map 24 Sheet 1, proposed to be revised <br />with this revision, the pipeline will be placed on the south side of Haul Road C. Based on Map <br />29, Sheet 4, this disturbed area along Haul Road C is partially within the Foidel Creek Stream <br />Buffer Zone at multiple location on the south side of the road. Given this, it would appear land <br />will be re -disturbed within the Foidel Creek stream buffer zone. Regardless if the area has been <br />disturbed already, TC must explain how they will protect the hydrologic balance during pipeline <br />installation, and afterward. Please revise section 2.05.6(3) (page 2.05-129) of the permit to <br />discuss what measures will be taken to comply with Rule 4.05.18(1)(a)(b) and (c). The Division <br />reviewed Exhibit 49S and 49K and could not find where TC has previously made the <br />demonstration how the pipeline disturbance will comply with Rule 4.05.18. <br />a. TC Response: The relevant text has been reviewed and revised to address protection of <br />the Hydrologic balance. The revised text pages accompany these responses for <br />replacement/insertion in the PAP. <br />b. Division Response: Resolved. <br />2. Exhibit 49S currently contains Drainage and Sediment Control System designs and SEDCAD <br />models to justify Alternative Sediment Control (ASC) practices for the 6RT Borehole Pad and <br />ov- • Coto <br />I e <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. Hickenboper, Governor I Mike King, Executive Director I Virginia Brannon, Director s 1876' <br />