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' • • III'llllllll llll 111 ` 999 The Pittsburg & Midway Coal Mining Co. Edna Mine (C-80-001) Permit Revision 03 Response to Colorado DMG Deficiencies September 7, 1993 INTRODUCTION The Pittsburg & Midway Coal Mining Co. (P&M) with this document addresses the Colorado Division of Minerals & Geology (DMG) deficiencies with Edna Mine's PR-03 submittal dated November 11, 1992, concerning the declassification of the Oak Creek Alluvial Valley Floor and the retention of the Center Ridge and the West Ridge Ponds as permanent impoundments. For format and clarity, DMG's deficiencies have been reiterated (italics) followed by P&M's response (normal). DEFICIENCIES AND RESPONSES 1) The Division has received proof of publication of your public notice in the Steamboat Pilot. The publication was published once on December 17, 1992. Rule 2.07.3(2) requires that the notice be published once weekly for four consecutive weeks. Please publish the notice three more weeks, and submit proof of those publications as soon as it is available. P&M contacted the Steamboat Pilot and instructed them to publish the public notices as required on the followed dates: February 18, 25, and March 4, 1993. Mr. David Beverlin was notified by the Steamboat Pilot that the remaining publications of the public notice were completed, hence the DMG was informed of the completed publications through correspondence dated April 5, 1993 from Mr. Beverlin. 2) Your application included a request to retain the Center and West Ridge Ponds as permanent impoundments. Rule 4.05.9 of the Rules and Regulations of the Colorado Mined Land Reclamation Board lists demonstrations required when designating permanent impoundments. Paragraph (d) of Rule 4.05.9 states that "Water impoundments shall not result in the diminution of the quality or quantity of water available to water right holders for agricultural, industrial, recreational, or domestic uses except in accordance with applicable State law." Does P&M have