2010-03-18_APPLICATION CORRESPONDENCE - C2009087

• Permit No: C2009087
• IBM Index Class Name: APPLICATION CORRESPONDENCE
• Doc Date: 3/18/2010
• Doc Name: Second Adequacy Response
• From: Peabody Energy
• To: DRMS
• Email Name: TAK
• Media Type: D
• Archive: No

Sage Creek Coal Company Responses to the CDRMS Additional
Adequacy Review of the Peabody Sage Creek Mine (C-2009-087) PAP
03/16/2010
The following responses address additional adequacy comments for the Peabody Sage
Creek Mine forwarded by CDRMS in letters dated February 11 and 16 and March 2, 5
and 11, 2010. Comments are addressed in this response document and appropriate
revised text sections, tables, figures exhibits, or maps included in the PAP and
accompany this response document.
5. Please provide the previously requested information: the description of the document
that provides Sage Creek Coal Company, LLC the right-of-entry provided by federal
lease COC088199 (which shows Sage Creek Holdings, LLC as the assignee). The
response provided a copy of the lease assignment, but the assignment is to Sage
Creek Holdings, LLC, rather than Sage Creek Coal Company, LLC. Also, please
make sure other right-of-entry documents that are described show Sage Creek Coal
Company, LLC as the grantee or lessee.
Response: A right of entry document providing Sage Creek Coal Company the right of
entry for private and Colorado surface and federal and Colorado coal leases including
federal lease COC088199 is included in Exhibit 2.03.6 -E1. The draft right of entry
document was reviewed by the Division and the Craig BLM office and approved.
Revised text pages at 2.03-16 and 16.1 are included with this response package.
10. Comment 10 in our letter of August 28, 2009 noted concern with calculations of
geometric means of hydraulic properties that combined data from two different types
of tests, constant head tests and slug tests. The Division cannot accept the grouping of
constant head and slug test data in the calculation of geometric means for
transmissivity and hydraulic conductivity of the Wadge overburden and underburden,
given the wide range of results from the small sample size obtained in two types of
tests. Please revise the permit application in accordance with either Alternative "A"
or "B", below.
Alternative A
Revise Table 2.04.7-T2 as follows:
a) Include only slug test data in the calculation of geometric means for the
Wadge overburden and underburden,
b) Show constant head data in the table separate from slug test data,
c) Identify data by test type (slug or constant head), and
d) Delete the overall geometric mean.
Remove the wording from the first paragraph on page 2.04-49 that begins with "The
grouping of wells...." and ends with "....consequences of the proposed mining," as