APPCOR12023

• Permit No: C2006085
• IBM Index Class Name: Application Correspondence
• Doc Date: 6/15/2007
• Doc Name: Permit Application Review Memo
• From: Mike Boulay
• To: Kent Gorham
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
INTEROFFICE MEMORANDUM
TO: Kent Gorham
FROM: MikeBoulay N1~7
DATE: June 15, 2007
SUBJECT: Northfield Mine, Permit No. C-2006-085
Permit Application Review
COLORADO
DIVISION OF
RECLAMATION
MINING
- &-
SAFETY
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cattany
Division DirecTOr
Natural Resource Trustee
I have reviewed the permit application materials for the proposed Northfield Mine and the
supplemental information submitted in response to our adequacy reviews of November 28, 2006
and December 15, 2006. I have the following adequacy review comments.
I agree with Northfield Mine's characterization and assessment of potential water quality and
quantity impacts with regard to groundwater in the underburden, the coal seam, and the
overburden. Their existing and proposed monitoring plan for these water-bearing units including
the Raton, Poison Canyon, and Vermejo Formations is acceptable. I agree that these are not
identifiable groundwater aquifers. No monitoring is indicated for the units underlying the Ocean
Wave Coal Seam due to an underlying aquitard and no potential for impact.
My primary question with the application and supplemental information is the lack of
characterization of the alluvial groundwater that exists for the gravels and alluviums along
Chandler Creek. The April 25, 2007 letter from BBA Water Consultants indicates on page 2 that
the alluvium of Chandler Creek is an alluvial aquifer system. Of significance is that in this letter
report, it is clearly stated that there are higher capacity wells completed in the alluvium of
Chandler Creek. Yet on page 2.04-16 of the application it is indicated that no units contain
significant or identifiable groundwater aquifers including the surficial colluvial/alluvial deposits.
All that is said about the alluvial groundwater in the permit application is that due to the aquitard
above the coal seam it is unlikely that there will be any impact to alluvial groundwater and under
the surface water section it is stated that the Chandler Creek and all are other drainages are
ephemeral. Under the surface water discussion Northfield further concludes that much of the
limited precipitation the area receives either infiltrates into relatively porous surface deposits or
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