2010-04-09_APPLICATION CORRESPONDENCE - C2009087

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i POLLUTION REPORT Air Pollution Potential: The proposed exploration activities will have little or no impact on local and regional air resources. The limited vehicular traffic to and from the drill sites has minimal potential to generate any significant quantity of dust from the existing county and ranch roads. The rotary drill-rigs will use foam/water mixture and an air mist to remove cuttings from the borings, thus minimal dust will be generated during the drilling process. Water Pollution Controls: The water pollution control plan focuses on the drill-sites where implementation of Best Management Practices (BMPs), i.e. rock check dams, silt fence, straw bales, etc., and limited pad size will effectively control runoff and sediment from the sites. Additionally, mud pits will be excavated at each of the drill-sites to contain any drilling fluids used during drilling operations. Following completion of the drilling and related activities the mud pits will be backfilled and the pad area reclaimed and revegetated. A Stormwater Management Plan (SWMP) was prepared for the 2008 exploration activities. The SWMP describes the controls Sage Creek uses to manage stormwater discharges from areas disturbed by the exploration activities. These are the same methods that will be used during the 2010 exploration activities. Please note that a Construction Stormwater Discharge Permit is not required. Discussions in June and July Of 2008 between Peabody Energy representatives and Water Quality Control Division. (WQCD) staff confirmed that a permit is not required (see Appendix D). The basis for the exclusion is: ® an individual disturbance is less than 1.0 acres ® cumulative disturbance is less than 5.0 acres • the individual disturbances are not part of a "Common Plan of Operations" ® a "Common Plan of Operations" applies to individual disturbances that are within 0.25 miles of each other, or which are connected by roads or pipelines Noise Abatement: None of the proposed drilling-sites are within 0.5 miles of a private residence. However, several of the sites are located near a county road. Only exploration sites ccu056 is within 0.25"miles of Routt County Road 27. The other exploration sites are a significant distance from any county road. Sage Creek plans to schedule drilling operations on a 12-hour per day basis (approximately 7:00am to 7:00pm); however, Sage Creek requests permission to conduct operations on a 24-hour per day basis if unforeseen delays cause the project to fall behind schedule. The exploration activities at any one drill-site should take about seven days; deeper holes (e.g., 1,900 feet) may take slightly longer. The type of equipment that will be used includes rotary drill-rig(s), water trucks, pipe trucks, pickup trucks, and miscellaneous support trucks. Landscaping: A landscape plan is not necessary given the limited nature of the exploration activities. The information provided in the reclamation plan addresses final site grading and revegetation for the drill-pads. 2010 RC Admin Permit 4 2124110