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Mike Boulay -2- May 22, 2008 <br />3. DRMS - Each application requires the location of each conveyance, treatment, storage, <br />and discharge facility to be used within the permit area. In accordance with Rule <br />2.05.6(3) (b) (vi), please identify the specific location where mine water will be <br />discharged. Please update pertinent sections of the permit application with a detailed <br />plan for handling the mine water discharge and describe how discharge standards will <br />be met. If the discharge is not conveyed through a sedimentation pond, provide a plan <br />for meeting applicable discharge standards including a copy of the CDPS discharge <br />permit, if applicable. If mine water is not treated by a sediment pond and discharged to <br />an ephemeral drainage, then the application shall contain a description and map of the <br />discharge point and the characteristics of the receiving water [Rules 2.04.5(1) and <br />2.04.7(2)(a)]. <br />CAM - Page 2.04-39 states there should not be any mine inflow during the initial permit <br />term. The AVF study shows where mine discharge, should it occur, would be <br />discharged. Page 2.05-100 states that mine discharge will be treated in underground <br />sumps if required. <br />4. DRMS - Please update the permit application sections 2.04.5, 2.04.7, and 2.05.6. to <br />include an impact analysis for Big Salt Wash. The Division will need this information for <br />input to a Cumulative Hydrologic Impact Analysis (CHIA) for the entire life of mining <br />operation. The PHC information and the CHIA will have to address impacts to both Big <br />Salt Wash as well as East Salt Creek. <br />CAM - There will be no impact to Big Salt Wash during the life of the operation so no <br />discussion is necessary. When CAM obtains the adjacent federal coal lease and <br />expands the permit boundary, the requested information will be provided. <br />5. DRMS - It is stated in the application that "The coal seam analytical data are obtained <br />from two grab samples from the McClane Canyon Mine and some historic information <br />from Snowcap Coal Company's permit." The geochemical analyses of the coal seam <br />and strata above and below the coal seam are presented in Volume III, Exhibit 6. Rules <br />2.04.6(3) (iii) and (iv) require site specific geologic baseline information for the lands <br />within the permit area. Rule 2.04.6(3) (b) does allow an applicant to request the Division <br />to waive in whole or in part these requirements. The waiver may be granted only if the <br />Division makes a written determination that the collection and analysis of such data is <br />unnecessary because other equivalent information is available to the Division in a <br />satisfactory form. To consider the application complete, the required site specific <br />geologic data is needed or a waiver request justifying the reasons why CAM-Colorado <br />believes site specific data is not necessary. <br />CAM - Rule 2.04.6(3)(a)(iii)(C) requires chemical analysis of the coal seam for acid- <br />forming materials including, but not limited to, the pyrite, marcasite and sulfur content. <br />Marcasite is a polymorph of pyrite which means it has the same chemistry as pyrite <br />(FeS2) but different structure of symmetry and crystal shape. Because of their <br />similarities they are reported to be very difficult to distinguish apart. Marcasite would be <br />included in the determination of pyritic sulfur content because the chemical composition <br />of the two are the same and therefore indistinguishable via chemical testing.