PERMFILE130794

• Permit No: C1981028A
• IBM Index Class Name: Permit File
• Doc Date: 10/26/2006
• Section_Exhibit Name: Application
• Media Type: D
• Archive: Yes

• ISSUES FOR CONSIDERATION
Description of changes to matters set forth in the original application for a permit or prior permit
renewal (2.08.5):
TABLE OF CONTENTS
I . General Permit review with goal of dcleting/archiving information relative to coal
mining operations, or solely in support of those operations. Replace, if appropriate,
with reclamation supportive [ext.
2. Mine Safety and Health Administration (2.03.5, pg 5) - By letter dated May 18, 1994,
MSHA transferred jurisdiction of the Keenesburg Mine site to the Occupational Safety
and Health Administration. References to MSHA should be changed to OSHA and/or
deleted, as appropriate, and file information relative to MSHA should be archived.
3. Monitoring wells (2.04.7, pg 56) located outside permit boundary -Both DH-96 and
DH-122 are located outside the permit boundary, one as the "upstream" control well
and the other as the "downstream" monitor well, checking the offsite effects of the
mining and ash disposal operations. Should concern be attached to the location of these
wel I s?
4. Rcvicw water sampling techniques (2.04.7, pg 56) -Propose to resume method
approved in current Permit, or some modification thereof, as opposed to technique
• presently employed which is the result of a 1994 OSM oversight inspection (see 1995
AHR Report).
5. Water used for Dust Suppression (2.04.7, pg 58) -Coors would like to explore with
the Division a possible use of the Fire Protection Well (formerly for the wal handling
facility) as a source of water for dust suppression on both the roads and in the ash
disposal area. The plugging and abandonment of LFH #2 (seemingly not covered in
documentation found in this permit) together with recent operational limitations on
LFH # l are straining the ability to provide adequate amounts of water for these
activities. While in need of testing to reconfirm its capabilities, it would appear that
the FPW has a more than adequate recharge capability to accommodate this use.
Operations Plan (2.05.3, pg 102) - It is suggested that this Section be archived entirely
and that the pertinent information which is still current be incorporated into Section
2.05.4 the Reclamation Plan. This is suggested only because all activities at the
Keenesburg site are now focused on the reclamation activity. Contrary to prior
statements, while some activities may not fit a strict definition of "reclamation", every-
thing presently done at the site contributes to reclaim, versus any further development.
Explosives and Blasting (2.05.3 pg 104) -All references should be deleted. Activities
anticipated to require any near term use of explosives have been completed. Inventories
of explosive materials have been exhausted, permits are now expired, and a close-0ut
inspection has been requested. '