2018-09-12_REPORT - C1982056

• Permit No: C1982056
• IBM Index Class Name: Report
• Doc Date: 9/12/2018
• Doc Name: Annual Reclamation Report Adequacy Review
• From: DRMS
• To: Peabody Energy
• Annual Report Year: 2017
• Permit Index Doc Type: Annual Reclamation Report
• Media Type: D
• Archive: No

9/20/2018 State.co.us Executive Branch Mail - Review of 2017 ARR for the Foidel Creek Mine (C-1982-056)
STATE OF Hernandez - DNR, Alysha <[e-mail]>
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COLORADO
Hernandez - DNR, Daniel <[e-mail]> Wed, Sep 12, 2018 at 1:49 PM
To: "Nettleton, Jerry" <[e-mail]>
Cc: Tabetha Lynch - DNR <[e-mail]>, Alysha Hernandez <[e-mail]>
Hi Jerry. A review of the 2017 ARR for the Foidel Creek Mine (C-1982-056) found that some of the information provided
in the 2017 ARR was transferred from the 2016 ARR without being updated for 2017. For your benefit, I've attached to
this e-mail the 2016 and 2017 ARR forms. Please submit a corrected 2017 Foidel Creek ARR form that addresses the
following items:
• "Acres backfilled and graded" row: In the "Acres backfilled and graded" row are 3 columns. These are (1)
"Last Year's Cumulative Total", (2) "This Calendar Year", and (3) "Cumulative Total". It appears the information
reported in the 2017 ARR in these 3 columns is the same information reported in the 2016 ARR. Please update
these three columns in the 2017 ARR.
• "Acres topsoiled" row: In the "Acres topsoiled" row are also 3 columns. These are (1) "Last Year's Cumulative
Total", (2) "This Calendar Year", and (3) "Cumulative Total". It appears the information in the 2017 ARR in these 3
columns is the same information reported in the 2016 ARR. Please update these three columns in the 2017 ARR.
• "Acres seeded" row: There are 5 columns in this row. The first 3 columns are (1) "Last Year's Cumulative Total",
(2) "This Calendar Year", and (3) "Cumulative Total". Again, it appears the information in the 2017 ARR in these 3
columns is the same information reported in the 2016 ARR. Please update these three columns in the 2017 ARR.
The 4th and 5th columns in the "Acres seeded" row are the "10 years or less" column and the "Greater than 10
years" column. It appears the information in the 2017 ARR that was reported in these 4th and 5th columns is the
same as the information that was reported in the 2016 ARR. Please address these numbers as well.
Two things are going on in the 4th and 5th columns. First, if any permanent reclamation seeding occurred in 2017,
then the "138.0" acres currently reported in the "10 years or less" column would need to be increased by however
many acres were seeded in 2017. Second, if any acres were seeded in 2006, which would have been eleven
years prior to any seeding that occurred in Calendar Year 2017, then that number of 2006 -seeded acres needs to
be subtracted from the "10 years or less" column and added to the "greater than 10 years column".
• "Long-term facilities" acreage: Once the above areas on the 2017 ARR form are updated, the next step is to
ensure that Foidel Creek's "Entire Life of Mine" disturbance acreage (currently reported as 742.9 acres) is equal to
the sum of the 2017 "Acres backfilled and graded" Cumulative Total (currently reported as 169.2 acres) and the
2017 "Long-term facilities" acres (currently reported as 589.6 acres).
Based solely on the numbers in the current 2017 ARR, it appears that the 589.6 -acre long-term facilities number is
15.9 acres too high (742.9 life -of -mine acres minus 169.2 backfilled -and -graded acres equals 573.7 acres, which is
15.9 acres less than 589.6 acres). Remember that the long-term facilities acreage number is the number of acres
of long-term facilities that have actually been built but that have not yet been backfilled and graded.
Thanks for your attention to these items Jerry. If there is any chance that the revised 2017 ARR could be sent to us
tomorrow, that would be great -- OSM sent me an e-mail this morning saying that I have just a couple more days to wrap
up our Annual Oversight Report, which includes numbers that operators report in their ARRs.
Dan
Daniel
Seniorro ' Protection Specialist
Mining and �Q
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