2018-04-02_REVISION - C1982056 - Laserfiche WebLink

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58. On October 30, 2015, the Division sent Mr. James A Tichener of Peabody Investment Corporation a letter. The letter indicated that it had come to the Division's attention that it had not received the required quarterly financial statements for 03131115, 06130115, and 09130115 pursuant to the above cited rule. The letter requested this information to be submitted by November 20, 2015. Please submit any updates to this information to the present quarter. Response: - The financial statements referenced, were required in conjunction with TC's self -bond for the Foidel Creek property. In April 2016, the self -bond was replaced with a surety bond and the CDRMS accepted the replacement surety bond and released the self -bond, so this requirement is no longer applicable. 4.05.13 (1) Groundwater Monitoring - Foidel Creek Mines' groundwater points of compliance are as follows: 97013TM (Twentymile Sandstone), 008-77-58 (Wadge overburden), 008-AU3 (Fish Creek alluvium), 008 -AT -1 (Trout Creek alluvium), and 008 -AV -2 (Foidel Creek alluvium). Please address the following issues: 59. It is not stated in the monitoringplan to what numeric standard the point of compliance wells are required to meet. Table 9 Summary of Groundwater Rights shows Domestic use wells within the POC monitored intervals. The Hydrologic Monitoring Plan needs to be updated to include the required numeric standard for the Point of Compliance well Analysis Parameters. It is currently not clear if the required numeric standards are to be meeting Domestic or Agricultural standards. Response: - Please refer to the discussion of "Ground Water Quality Protection" on page 2.05-130 and the extensive discussion of "Potential Mining -Related Impacts on Ground Water Quality and Quantity" on pages 2.05-133 through 2.05-149. The Foidel Creek Mine mining and related operations will all occur within the Twentymile Park groundwater basin, which is an enclosed basin with little or no potential for groundwater movement out of the basin. The CDRMS has recognized this, as documented in the Permit Renewal RN -05 Decision and Findings of Compliance; "The Wadge overburden and the Twenrymile Sandstone are the two major aquifers most likely to be affected by the Foidel Creek Mine.... The mine's annual hydrology reports contain long-term data . from these wells. These data show Foidel Creek Mine is in compliance with the Basic Standards for Ground water at the groundwater points of compliance. " All of the groundwater rights identified in Table 9 are owned by either TC or Sage Creek Land & Minerals, an affiliated Peabody subsidiary company. There are currently no domestic or agricultural uses of groundwater within the Twentymile Park basin, so the applicable groundwater quality classification under Regulation 41, Basic Standards for Groundwater, would be "Potentially Usable Quality". Based on this classification, and the lack of current existing uses, the only applicable water quality standard is TDS, which is 1.25 x background levels. Both the water monitoring discussion in the PAP and Water Monitoring Plan (Exhibit 14) have been revised to clarify points of compliance and this compliance threshold and copies of the revised permit materials are included with these responses for replacement in the PAP. 60. Have the proposed wells WC008A and WC013A been installed (monitoring program Exhibit 14A)? They are shown on Map 13A, but have not been acknowledged as current monitoring wells in the monitoringplan. Response: - The referenced wells have been constructed and are being actively monitored (refer to MR's 14-279 and 14-281), and the Hydrologic Monitoring Plan (Exhibit 14) has been reviewed and updated to include these wells. Copies of the revised permit materials are included with these responses for replacement in the PAP. 61. The Annual Hydrology Reports (AHRs) reference potentiometric surfaces within the written interpretation of the data and they are referenced within the permit related impacts to the hydrologic balance; however, these potentiometric surfaces are not currently being provided within the AHR. Due to the potential impacts from dewatering to the hydrologic balance, as well as the potential for increased aquifer communication due to subsidence, it is appropriate to include potentiometric surface maps with the annual hydrology report going forward. Please provide the Division with potentiometric surface maps for the Wadge Overburden, Twentymile Sandstone, Trout Creek Sandstone, and Fish Creek Sandstone bedrock units.