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Mr. Trralialda~fad~ <br />© Diusim of Mvierals arrt Gmtogy <br />NocarJxr 5, 1999 <br />Page 2 <br />r1 <br />L J <br />Section 31: <br />(Portion of) IVE'/. 1.03 acres <br />(Portion oE] W 'fe 1.14 acres <br /> 8.92 acres (total) <br />Attachment C contains a map of the HG Coal Company 1999 Permit Boundary prepared by <br />Epp & Associates (Professional Land Surveyors) which presents Metes and Bounds <br />descriptions for the four areas within the revised pemut boundary. <br />Comment 3 Permit does not specify a monitoring program for slump. Future lend mlav~e <br />for the sltmtp pattrl aen/1 depend on a dar»tstration of stnrcun-al stabi/t'ty Hutotical maritore:g data ¢eadd he <br />nerssary in order to make such a danertstratiaz 7lx pemrit does mt de.~crrlx sucpi a mazimrvrg progran; tlxrejore, <br />the Diursicaz nr/ttests that a manitrnvtg program lx sp~ifral in the pemrit appliratiarr. <br />Response: A Minor Revision (MR-13), Slump Investigation and Mitigation Report, was <br />submitted in April 1998. This report indicated that visual observations of the temporary <br />movement monuments showed no apparent movement of the slump azea from 1995 through <br />October 1997. H-G Coal Company will conduct bi-annual visual inspections (in the spring <br />and fall) to document the stability of the slump area. It is proposed to take photographs of <br />the azea during the visual inspections to provide permanent documentation. If noticeable <br />movement is observed the Division will be notified and mitigative measures will be developed <br />and implemented if deemed necessary. <br />• Comment 4 Permit does not adequately describe the hydrologic monitoring plan. 17x <br />pemut application descnlxs tlx mmitorvmg p/~m chat wu follaual prior to tle r[ceu bawl n~ease. To enszae <br />mrrplia»~ wit{i $ftY![n 2.05.6(3J(ruJ, p~+se uprlc+te tle descriptiae ojthp mmitorvtg plan and explain thx ta~irrt~tl <br />basis jor raan dxm~es nz the morarorirtg plmt. <br />Response: A hydrologic monitoring program is no longer needed at the Hayden Gulch Mine. <br />The Division has indicated to HGCC in various correspondence that HGCC no longer needs <br />to conduct hydrologic monitoring activities. During the Phase II/III field inspection the <br />Division approved HGCC's request to abandon all monitoring wells. Abandonment was <br />completed in October 1998. <br />The Division stated in the permanent impoundment determination that the "monitoring data <br />indicate a trend in quality that will be swtable for livestock and wildlife use, and will comply <br />with NPDES limitations, CWQCC basic surface water standazds, and CWQCC instream <br />standazds." In addition, the Division concluded "that discharge from impoundments will not <br />cause material damage to existing or future water users downstream...." The Division also <br />concluded as part of the bond release findings that HGCC no longer needs to conduct water <br />monitoring activities at the Hayden Gulch Mine. A copy of a letter approving HGCC's <br />request [o discontinue the water-monitoring program is included as Attachment D. <br />Cht September 10, 1999, HGCC submitted a Pemut Terminauon Fortn to the Colorado Water <br />Quality Control Division requesting termination of the existing CDPS pemut (COG-850018) <br />based on the discontinuance of the surface water monitoring program as approved by the <br />Division. The Water Quality Control Division approved the termination request in a letter to <br />HGCC dated October 29, 1999. The termination approval is included in Attachment D. <br />• <br />Tk-G$ <br />JAN 1 3 2000 <br />