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Mr. Michael S. Savage June 26, 1996 -Incomplete App. Page 2 agrees that it approved Permit No. C-92-080 with the information currently provided in the application; however, OII's lack of contemporaneous reclamation of the North Pit was not approved. The Division is concerned that the North Pit may be a cause of the somewhat acidic water described in the Division's Mid-Term Review. When Dr. James Pendleton of our Division reviewed the designs for the Carbon Junction Canyon durable rock fill, he did so in accordance with the regulatory criteria that existed at the time of his review. The permit for which Dr. Pendleton's review was conducted (Permit No. C-82-054, Pueblo Coal Company) has, however, since been revoked. As such, OII's current permit for the Carbon Junction Mine (C-92-080) must be in compliance with current regulatory criteria. This is especially important in light of the fact that the currently-active gravel mining operation, situated with the Carbon Junction coal mine permit boundary, was not an activity approved under the revoked Carbon Junction coal mine permit (Pueblo Coal Company, Permit No. C-82-054). As such, Dr. Pendleton's review did not evaluate the effects of the material being placed on the rock fill by the gravel operation. Finally, with regard to our statement that the rock fill "was erroneously approved," perhaps a better way of stating out point was not to have used this phrase. Nevertheless, OII has agreed that "steps need to be taken to provide for surface drainage containment and diversion" and that "OII's consultants...are in the process of developing designs which will satisfy Division concerns" (Page 6, June 18, 1996 Mid-Term Review responses). We commend OII for moving forward with revising the existing Carbon Junction mine permit at this time to more adequately meet current regulatory criteria. We apologize for any undue concerns our comments we may have created. 6) A revised groundwater monitoring plan, reflecting currently-approved water quality evaluation parameters, was not submitted. The Division will be happy to meet with OII to discuss this revised plan; however, this TR cannot be deemed complete without the revised plan. 7) A revised determination of the probable hydrologic consequences was not provided. As the groundwater monitoring plan is required to be based upon the probable hydrologic consequences determination (Rule 2.05.6(3)(b)(iv), and as the groundwater monitoring is proposed to be revised, the PHC determination should be revised to reflect the revised groundwater monitoring plan. The PHC determination should additionally be revisited to address any new potential surface water quality, quantity, and flow rate impacts that could be caused by the unreclaimed North Pit and the gravel operation's placement of material on the Carbon Junction Canyon rock fill.