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<br />DESERADO MINE <br />BLUE MOUNTAIN ENERGY <br />3607 County Rd. 65 <br />Rangely, CO 81648 <br />(970)675-4300 <br />fax (970)675-4399 <br />Apri18, 2008 <br />Mr. Jason Musick <br />Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />O??'M?p??9 aid Safer) <br />RE: Technical Revision #65 - Response to 2007 Midterm Review comments <br />Deserado Mine - Permit No. C-1981-018 <br />Dear Jason: <br />Enclosed is a technical revision (TR-65) addressing the Divisions comments provided in <br />the 2007 Midterm Review. The following addresses the <br />1. Item resolved. <br />2. We agree to modify the language on page III-18 as proposed except for <br />monitoring prior to the longwall advancing beneath the County Road 65. <br />Extensive observations at the Deserado Mine, including monitoring for <br />subsidence cracks on County Road 65 and monitoring degas boreholes, clearly <br />show that the surface effects of subsidence lag about 50 feet behind the active <br />longwall. Therefore, the proposed language was modified to require <br />monitoring to commence when the longwall has advanced under the road right- <br />of-way. <br />3. Item resolved. <br />4. The parameters listed on the tables provided by the Division may reflect <br />applicable water quality standards but do not constitute a list of parameters that <br />coal mining in Colorado would or could reasonably impact. They only provide <br />a list or parameters to consider when formulating a sampling plan. We cannot <br />agree to use this all inclusive list blindly as a parameter list for monitoring the <br />POC. The Colorado Department of Public Health and Environment has <br />compiled a list of parameters that they feel that coal mining could potentially <br />impact. This list is part of BME's NPDES permit and shown on Table VI-7 of <br />the Colorado Discharge Permit System Summary of Rationale (see attached). <br />The standards upon which this list was compiled reflect protection of beneficial