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-2- I. Decision to Require Revision The Division has conducted amid-term review under Rules 2.08.3, 2.06.2(a), 2.06.3(4), 2.06.5(3), 2.06.7(5) and 3.02.2(4). The Division finds that certain revisions and modifications are needed to ensure future compliance with the Colorado Surface Coal Mining Reclamation Act and the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. The following section details the revisions required and a justification for requiring the revisions. Section IA responses should be submitted as a request for revisions by November 29, 1984. IA. Revisions Required 1) Section 2.03.10 (page 5) of the permit application states the Air Pollution Control Division - Colorado Department of Health Emission Permit and the Colorado Department of Health - NPDES permits have been applied for. Copies of these permits must be submitted to the Division. 2) Section 2.05.3(2)(b) of the regulations requires appropriate map(s) and timetable(s) sufficient to describe the areal extent of the proposed underground workings. Exhibit 6 of the application appears to show the mine workings as of February 4, 1981. This map needs to be revised to show the current workings and the extent of the planned workings as of the end of the current permit period. 3) As required by Regulations 2.05.6(3) the applicant has submitted a plan for monitoring water quality. However, the plan does not specify sampling periods, or describe what chemical analyses will be performed if the initial samples exceed the propsed limits for pH, conductivity and T.D.S. Also the plan does not specify reporting times as described in Section 4.05.13(2). Without this information the Division cannot determine if the operator is ensuring the protection of the quality of surface and ground water within both the proposed permit area, and adjacent areas, from adverse effects of the surface or undeground mining activities as required by Section 2.05.6(3) - Protection of Hydrologic Balance. The operator must submit a plan which will detail the sampling parameters, time periods and reporting times. An acceptable plan, which could be submitted as a minor revision to replace page 16A of the permit application is enclosed with this mid-term review. IB. Advisorv Comments The following item was identified during the review that pertains to an issue which is not subject to the November 29, 1984 response date, but which should be considered during the permit term. 1) Several references were made in the application to a pending Federal Lease for an additional 120 acres of coal. The Division should be appraised of the current status of this application.