2019-06-20_REVISION - C2009087 - Laserfiche WebLink

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1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us Jared S. Polis, Governor | Dan Gibbs, Executive Director | Virginia Brannon, Director June 20, 2019 Jerry Nettleton Peabody Sage Creek Mining, LLC 29515 Routt County Road #27 Oak Creek, CO 80467 RE: Sage Creek Mine; C-2009-087: Minor Revision No. 31 (MR31) Adequacy Review No. 2 Dear Mr. Nettleton: The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed the Peabody Sage Creek Mining, LLC’s (PSCM) responses, received on 4/30/2019, to the Division’s preliminary adequacy review for the above referenced minor revision. PSCM’s proposed revised pages have extraneous information as well as unclear wording that that the Division requests be removed and/or rephrased:  On page 2.04-147A, second paragraph, please consider revising the second paragraph stating “The initial straw bale placement methods are consistent with both this commitment and the stated reclamation objectives of preserving or enhancing site environmental value.” Please note that the straw bale placement methods are not a requirement by the Division as a part of the Peabody Sage Creek Mine’s approved reclamation plan.  On page 2.04-147A, fourth paragraph, it is stated that “It should be noted that since the drainage area for Pond 004 has been bond-released and Pond 004 has been approved as permanent postmining structure, the noted Pond 004 wetlands enhancements represent postmining management measures not subject to CDRMS permitting.” The Division agrees with this statement, however a similar statement has not been included for the activities proposed downstream of Pond 002, and the wording in the revised pages still indicates that these enhancements are necessary to protect the hydrologic balance and meet stream standards. If the intention of the operator is to add sediment control structures, or to inform DRMS of activities within the permit boundary that are not related to mining and reclamation, please add text to the proposed revised pages accordingly.  Please consider omitting the third paragraph on page 2.04-147B beginning “Based on comparison of water quality sampling results…” This paragraph implies that these enhancements are a necessary aspect of the mining and reclamation plan to protect the hydrologic balance, to meet stream standards, and required by the Act and Rules. The Division is not requiring the activities to be conducted as a part of the operation or reclamation plan for the Peabody Sage Creek Mine.