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Hydro-Environmental Solutions, Inc. <br />hydrology, water quality and environmental consulting services <br />November 16, 2007 via FedEx: 862898904777 <br />Mr. Daniel Hernandez <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Re: - Hayden Gulch Loadout, Permit C-92-081 <br />Minor Revision No. 16 (MR-16) <br />Responses to Coal Bond Compliance Inspection and Change of Compliance File Location <br />Dear Mr. Hernandez: <br />On behalf of Hayden Gulch Terminal, Inc. (HGTI), enclosed are three (3) copies of an application <br />for a minor revision to the Hayden Gulch Loadout (Loadout) Permit (C-92-081). Minor Revision <br />No. 16 (MR-16) presents HGTI's responses to the Colorado Division of Reclamation, Mining and <br />Safety's (CDRMS) Coal Bond Compliance Inspection dated August 17, 2007. In addition to <br />responding to CDRMS comments of August 17, 2007, the minor revision application also contains <br />revised Permit Application Package (PAP) material that changes the location of the compliance file. <br />HGTI proposes moving the file to the Peabody Energy office that is located at the Loadout facilities <br />area. <br />The CDRMS's comments from the August 17, 2007 letter are provided below in italics followed by <br />HGTI's response. <br />Item 1. With reference to the introduction of the report, the PAP was found to not contain clearly <br />defined general (Rule 2.05.2) or specific (Rule 2.05.3) operation plans for the site. Please <br />develop and incorporate such plans into the PAP. A question that arose is: "What is the <br />currently approved operation - coal load in, or coal load out? Or both? " Please formulate <br />the plans to clearly define the permitted operation (s). <br />Response: Tab 1, Permit Summary, as noted by the Division serves as an introduction to the PAP. <br />It provides the reviewer with a brief summary of the facilities ownership and permit history, as well <br />as an overview of the operational plan. <br />The PAP provides a description of both rail loadout and load-in operations. The rail loadout <br />operation is the operational plan originally approved for Permit C-92-081 (permit issue date of May <br />22, 1993). All the coal handling equipment for the railcar loadout operation is existing and on-the- <br />ground. Technical revision No. 6 (TR-06), which was approved in June 2005, permits the <br />retrofitting of the coal handling facilities to allow railcar unloading and truck haulage operational <br />plan. However, the facility retrofit approved with TR-06 has not been implemented and none of the <br />equipment described as part of TR-06 has been constructed. Tab 1 has been revised to clarify that <br />the Hayden Gulch Loadout is a coal handling facility that is currently configured as a coal loadout, <br />but has been approved to change the operational plan to a coal load-in. Other sections of the PAP, <br />as appropriate, have been revised to clarify the operational plan. <br />P.O. Box 772996 <br />5710`" Street, Suite B <br />Steamboat Springs, CO 80477 <br />970-871-6125 * 970-871-6196 (fax)