2008-06-05_APPLICATION CORRESPONDENCE - C2008086

• Permit No: C2008086
• IBM Index Class Name: APPLICATION CORRESPONDENCE
• Doc Date: 6/5/2008
• Doc Name: Adequacy Letter
• From: DRMS
• To: CAM-Colorado, LLC
• Email Name: MPB
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
June 5, 2008 Governor
Harris D. Sherman
Executive Director
Gary Isaac
Ronald W. Cattany
CAM-Colorado, LLC Division Director
P.O. Box 98 Natural Resource Trustee
Loma, Co 81524
Re: Red Cliff Mine (Permit No. C-2008-086)
New Application
Dear Mr. Isaac:
The Division of Reclamation, Mining and Safety (Division) has reviewed CAM-Colorado LLC's
responses to our initial completeness review for the new permit application to conduct coal mining in
Colorado for the proposed Red Cliff Mine. The application, submitted by CAM-Colorado was received
on April 25, 2008. The Division responded with our completeness review on May 5, 2008 and deemed
the application incomplete. On May 27, 2008 we received CAM-Colorado's responses to our
completeness review letter. Based on our review of your responses all of the Items 1-11 of our initial
completeness review have now been minimally addressed, with exception of Items 2, 3, and 6. Thus, your
application is deemed incomplete for the purposes of filing as of June 5, 2008 for the reason described
below. The Division has the following remaining comments regarding the 11 items initially identified in
our May 5, 2008 completeness review.
1. Response accepted.
2. The discussion of mine water discharge remains an issue. Based on the information provided in
CAM Colorado's response and the permit application package, there does appear that there will be
mine inflow during the life-of-mine operation. CAM has stated in the response and on page 2.04-
39 that there should not be any mine inflow during the first permit term. However, the narrative
on page 2.04-22 provides an estimated future inflow rate after several years of mining up to 250
gpm. Maps 10 and 14 indicate that saturated conditions will be encountered during year six
(which is within the life of mine) and there is still an incomplete discussion of the handling, plan
for treatment and potential for discharge from the mine during the life of the operation. Rule
2.0.5.6(3)b) (ii) requires a plan for treatment for groundwater drainage from the area and proposed
quantitative limits on pollutants in discharges subject to applicable State and Federal laws. There
is no discussion in the Probable Hydrologic Consequences [2.05.6(3) (b) (iii)] regarding the
impacts of mine discharge during the life of operation. Therefore, CAM-Colorado has not
minimally addressed the requirements of 2.05.6(3).
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines