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RN07 Page 22 5/30/18 Please review the results of the relevant hydrologic monitoring data and provide an assessment of the mining impacts on the Fish Creek AVF and include it in the subsidence report discussed in the item above. Response: - The referenced hydrologic monitoring is part of TC’s ongoing hydrologic monitoring program, as approved under our hydrologic monitoring plan. The noted monitoring activities have been, and continue to be conducted, consistent with the approved monitoring schedule, to document current conditions and allow identification and assessment of any significant changes that may be related to the ongoing mining activities. While not included in a subsidence report, as noted in the previous response, the results of this ongoing hydrologic monitoring and the related assessment is documented and reported in the Annual Hydrology Report submitted to the CDRMS. In order to avoid future confusion, the reporting reference noted has been modified to reflect these considerations, and copies of the revised text are included with these responses for replacement in the PAP. DRMS May 2018 Response The approved subsidence monitoring included with recent AHR reports for the impacts related to Fish Creek is insufficient. The proposed page 2.05-191.7 of the renewal states that, “The results of ongoing hydrologic monitoring are included and evaluated in the Annual Hydrology Report.” This was the monitoring plan approved by the Division in PR-08. The AHRs have not been adequately following this plan. The 2016 and 2017 reports have a subsidence section included in section 4.0; however, the section refers the reader to the reports by Michael Berdine dated May of 2017 (2017 AHR). This is contradictory to the approved monitoring program. Section 4.0 in the AHRs does not include an analysis of the data from these reports. Section 5.0 only includes general statements of there being no new subsidence impacts to Fish Creek and a few sentences regarding historical impacts. Future AHRs should include an analysis of the Fish Creek subsidence data and water quality data in Section 4.0 to satisfy Rule 2.05.6(6)(c). 3.02.4(2)(e)(i)(D) Performance Bond 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 03/31/15, 06/30/15, and 09/30/15 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. Resolved 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 monitoring plan 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.