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Mike Boulay -3- May 22, 2008 <br />CAM does have sulfur analysis of coal samples from the permit area. The sulfur <br />analysis includes pyrite, sulfate, organic and total sulfur from four exploration holes <br />drilled in September and October 2004. Attached is a summary of the sulfur analysis of <br />coal that should be inserted into Volume III, Tab 6. Should the DRMS deem this <br />information inadequate, please waive the requirement for permit specific coal analysis. <br />The analysis of the coal from the McClane Canyon mine should be representative of the <br />coal mined from the Red Cliff Mine because the two mines will be extracting coal from <br />the Cameo Seam. Additionally, the McClane Canyon Mine coal sample came from <br />active mining that is only about one-half mile north of the proposed Red Cliff Mine permit <br />boundary. The main focus of the analysis is the determination if the coal seam contains <br />acid-forming materials. Experience at Roadside, Cameo, Munger and McClane Canyon <br />Mines indicates the Cameo Seam does not have acid-forming properties. <br />6. DRMS - In accordance with 2.04.7 and 2.05.3 please provide a spring and seep survey <br />for the entire estimated life of mine operations area and clarify the location of the springs <br />referenced on page 2.04.9. <br />CAM - The DRMS' comment is noted regarding a spring and seep survey. <br />7. DRMS - The baseline surface water data presented for East Salt Creek appears to be <br />lacking the some the minimum parameters required by Rule 2.04.7(2). For ESC-1 both <br />total and dissolved iron are required and at ESC-2 total suspended solids, iron, and <br />manganese appear to be missing from the analyses. If these data are available please <br />update Volume III, Exhibit 3 accordingly. <br />CAM - The missing data are not available. CAM will collect the requested data as part <br />of its continuing baseline collection program. <br />8. DRMS - The Alluvial Valley Floor Determination presented in Volume III, Exhibit 12 does <br />not specifically include the information identified by our Division in a letter dated May 22, <br />2006 regarding our informal alluvial valley floor findings. The AVF study also appears to <br />be lacking detailed operational information (for example mine water discharge locations), <br />There are two areas of alluvium that need to be addressed one along East salt Creek <br />and one along Big Salt Wash. These specifically are where mine water discharge enters <br />East Salt Creek down to the Highline Canal. Likewise, to the east where mine discharge <br />would likely enter into Big Salt Wash down to the Highline Canal. The Division believes <br />that AVF Study needs to be revised to include these areas of alluvium and the letter from <br />Mr. Dan Mathews of our Grand Junction Filed Office regarding our informal alluvial <br />valley floor opinion should be incorporated into Exhibit 14 of the permit application <br />package. <br />CAM - The request to modify the AVF study is noted. Enclosed is the referenced letter <br />from Mr. Dan Mathews to be incorporated into Volume III, Book 2 of 2, Exhibit 14 of the <br />permit application package. <br />9. DRMS - Surface disturbance associated with ventilation shafts was not identified in the <br />application. Please update the application to include all disturbances associated with <br />vent shafts including the required road construction to access the shaft sites.