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jurisdiction of the Colorado State Engineer's office. We believe this procedure is consistent with <br />the provisions of CDMG Rule 4.05.14. Colowyo does not believe the Divisions's rules prohibit <br />our intended course of action. The Division has failed to address whether our proposed <br />management scenario would have any adverse effect on the environment, health or safety. <br />Unless such a finding is made we don't believe the rules are intended to extend perpetual CDMG <br />jurisdiction over subsequent proper management and uses after all coal exploration activities <br />have ceased. Should any issues remain, Colowyo, respectfully, requests an opportunity to <br />discuss the issue further with the Division at your earliest convenience. <br />In the Division's November 20, 2000 Midterm Review for Permit C-81-019, Items 14, and 15 also <br />provide a duplicate request for additional information relative to wells located within 1 mile of the <br />Permit boundary. Colowyo proposes to address this specific TR-50 request through the midterm <br />review process rather than the TR-50 process. <br />Item #2 and #3 - We believe the most appropriate location for this TR-50 information would be in <br />the Exhibit 6 -Geologic Information. <br />We have attached a Table of Contents page for Exhibit 6 -Geological Information. We have <br />included TR-50 as Item # 5 in this Exhibit. Both the Table 1 and the Permit Area 1989-1997 Drill <br />Hole Information Map should be placed into this exhibit. <br />Item # 4 - Colovryo checked with a number of people having historic knowledge about the drilling <br />activities in the early 1970's, the time during which these holes in question were drilled. The <br />consensus appears to be that the drilling activities occurred before any State regulatory authority <br />was in place to regulate such activities. As such, we believe that such activities were "pre-law" <br />and not conducted under any State mining and reclamation agency approvals. Further, we <br />believe there were no bonds submitted payable to Colorado for the reclamation of the sites. A <br />review of Map 10 indicate that all of the sites with the exception of 5/A6 and 26 have been <br />disturbed by mining. 5/A6 will eventually be disturbed by mining in the West Pit. Colowyo does <br />not intend to use these pre-law wells. <br />Item #5 -The holes IP#1, IP#2 and IP#3 permitted under MR-44 were never drilled (per Juan <br />Garcia.) Table 1 has been corrected to include the information. In addition, the 89 - 97 Map has <br />also been updated to show these proposed drill hole locations. <br />Item #6 -Table 1 and the 89-97 Map have been updated with the information regarding the <br />twelve MR-44 drill holes in question. As the Division is aware, the holes were drilled within the pit <br />disturbance and thus, not bonded. <br />Item #7 - As requested, drill hole 89-10-6 information has been included in Table 1. <br />Item #8 -The Division suspected that hole UL-95-40 was listed incorrectly. We believe this item <br />is correct and there should be bond-in-place. However, the hole noted in the line above, UL-95- <br />32 has not been mined through, is still in place, and it should have abond-in-place of $2,737.00 <br />rather than a bond credit. Table 1 has been modified to correct the error. <br />Item #9 -Pages 2.05-58, 4.07-1, 4.21-2 and 4.21-3 are included herein and modified to include <br />the suggested language. <br />Item #10 - UL-95-40A and UL95-45A are the correct Colowyo designations for the monitor wells. <br />The Monitor Well map has been changed to reflect the correct designation. The discrepancies <br />occurred as a result of the failure of the Licensed Water Well Contractor to file the correct Well <br />