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Peabody Sage Creek Mining, LLC <br /> Sage Creek Mine — Permit C-2009-087 <br /> MR31-18 Wetlands Enhancements — TA2 Responses (06/26/19) <br /> 1) On page 2.04-147A, second paragraph,please consider revising the second paragraph stating, "The <br /> initial straw bale placement methods are consistent with both this commitment and the stated <br /> reclamation objectives of preserving or enhancing site environmental value. " Please note that the <br /> straw bale placement methods are not a requirement by the Division as a part of the Peabody Sage <br /> Creek Mine's approved reclamation plan. <br /> Response: Notations have been added, as noted, to reflect that the wetland enhancement activities are a <br /> postmining land management activity which is not part of the approved CDRMS reclamation plan. Copies <br /> of the revised pages accompany these responses for replacement in the PAP. <br /> 2) On page 2.04-147A,fourth paragraph, it is stated that "It should be noted that since the drainage <br /> area for Pond 004 has been bond-released and Pond 004 has been approved as permanent postmining <br /> structure, the noted Pond 004 wetlands enhancements represent postmining management measures <br /> not subject to CDRMS permitting. " The Division agrees with this statement however a similar <br /> statement has not been included for the activities proposed downstream of Pond 002, and the wording <br /> in the revised pages still indicates that these enhancements are necessary to protect the hydrologic <br /> balance and meet stream standards. If the intention of the operator is to add sediment control <br /> structures, or to inform DRMS of activities within the permit boundary that are not related to mining <br /> and reclamation,please add text to the proposed revised pages accordingly. <br /> Response: The referenced statement has been modified so that it is non-specific and applicable to the <br /> proposed wetland enhancement activities for both sites. Also, the language pertaining to protection of <br /> hydrologic balance and prevention of off-site hydrologic impacts has been reviewed and revised to note <br /> that, as postmining land management measures, the proposed activities are supplemental and go beyond <br /> the permitted and reclamation plan requirements. Copies of the revised pages accompany these responses <br /> for replacement in the PAP. <br /> 3) Please consider omitting the third paragraph on page 2.04-147B beginning "Based on comparison of <br /> water quality sampling results... " This paragraph implies that these enhancements are a necessary <br /> aspect of the mining and reclamation plan to protect the hydrologic balance, to meet stream standards, <br /> and required by the Act and Rules. The Division is not requiring the activities to be conducted as a <br /> part of the operation or reclamation plan for the Peabody Sage Creek Mine. If it is the case that <br /> PSCM believes these activities are needed due to PSCM not protecting the hydrologic balance, the <br /> proposed enhancements would be considered mining and reclamation activities and a technical <br /> revision will need to be submitted so that a more thorough review of water quality and stream <br /> standards can occur. <br /> Response: The referenced paragraph was reviewed and revised consistent with the changes noted in the <br /> responses to Items 1 and 2. Copies of the revised pages accompany these responses for replacement in <br /> the PAP. <br /> 4) Please consider revising the wording "natural passive treatment" within the revised pages, as these <br /> sites are not permitted by the Division or another agency as treatment systems. <br />