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IIIIIIIIIIIIII I <br />_ (**G/ MONTGOMERY WATSON <br />i // Mining Group <br />October 21, 1998 <br />Mr. Michael Boulay <br />Colorado Department of Natural Resources <br />Division of Minerals & Geology <br />1313 Sherman Street <br />Room 215 <br />Denver, Colorado 80203-2273 <br />RECEIVED <br />OC7 2 3 1990 <br />DIV. OF MINERALS <br />8 GEOLOGY <br />RE: RESPONSE TO AGENCY STIPULATION NUMBERS 7 AND 9; <br />SENECA COAL COMPANY'S YOAST MINE <br />OPERATIONS AND RECLAMATION PLAN <br />This correspondence from the Montgomery Watson Mining Group (MW) addresses the <br />Colorado Division of Minerals & Geology's (DMG's, or the "Division's' 1995 permit <br />Stipulations 7 and 9, regarding potential hydrologic and hydrogeochemical impacts to Sage <br />Creek from mining activities at Seneca Coal Company's (BCC's) Yoast Mine, located near <br />Hayden, Colorado. The agency stipulations apply to the Operation and Reclamation Plan <br />(the `permit') subrrtiued by SCC for activities at the Yoast Mine, and the stipulations <br />include agency comments to the original permit submittal. Cited Stipulation 7, 9, and the <br />respective MW and SCC responses are addressed below. <br />STIPULATION NO. 7 <br />PRIOR TO INITIATING ANY MINE RELATED DISTURBANCE IN THE SAGE <br />CREEK WATERSHED, THE APPLICANT SHALL COMPLETE EVALUATION OF <br />THE PROBABLE HYDROLOGIC CONSEQUENCES OF PROPOSED MINING <br />OPERATIONS IN THE SAGE CREEK WATERSHED. THE EVALUATION SHALL <br />ADDRESS POSSIBLE MATERIAL DAMAGE IN TERMS OF POTENTIAL <br />DEGRADATION OF WATER QUALITY OR QUANTITY WHICH MIGHT <br />RESULT IN IMPAIRMENT OF PRESENT WATER USES WHICH CANNOT BE <br />MITIGATED OR LONG-TERM IMPAIRMENT OF EXISTING OR POTENTIAL <br />WATER USES. <br />The issues of concern presented above are addressed in permit Tab 17 (Probable Hydrologic <br />Consequences), which includes discussions regarding potential impacts to water rights, <br />surface water and groundwater flow, and hydrogeochemstry for all drainages within the <br />Yoast permit boundary and adjacent areas, including the Sage Creek watershed. The <br />potential impacts to Sage Creek discussed in Tab 17 are briefly summarized as follows. <br />Water Rights <br />Complete descriptions of the surface water and groundwater rights, as well as unrighted <br />water sources within and proximate to all areas of the Yoast Mine (including those in Sage <br />Creek) are contained in permit Tab 16 (Water Rights and Alternative Water Supplies). <br />P.G. Boz 774018 Te I: 97D 879 6260 <br />1475 Pine Grove Road Fax: 9708799048 Serving the World's Environmental Needs <br />Steamboat Springs, Colorado <br />80477 <br />