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Mr. Kent Gorham <br />June 3, 2011 <br />Page 2 <br />Rule 2.03 Legal, Financial, Compliance, and Related Information <br />1. DRMS: In the DRMS/OSM Applicant Violator System (AVS), Earnest Cleave is listed <br />as a manager with a beginning date of January 4, 2010. However, he is not listed in the <br />revised permit materials for PR-02. Please revise page 2.03-4 (revised 2/10) or submit an <br />end date so that the AVS can be updated. <br />NECC response: Earnest Cleave is a manager. Please withdraw page 2.03-4 from <br />consideration in PR02. <br />Rule 2.04 Information on Environmental Resources <br />2. DRMS: Please re-submit those permit text narrative pages submitted under Rule 2.04 <br />(2.04-5 to 31, not all inclusive) with the changes required as a result of the adequacy <br />response to question #2 of the Divisions adequacy letter of March 24, 2011 for TR-56 <br />(below in italics). Pages 2.04-8 to 11 under PR-02 are now in conflict with pages <br />recently approved under TR-55. (please also note page 2.04-8 is the second side of a two- <br />sided page). Also, please ensure that currently approved permit text narrative presenting <br />baseline information is retained to the extent that the information is still accurate and <br />representative for the expanded permit area. <br />Permit text narrative on pages 2.04-17 to 2.04-25 describe the groundwater hydrology as <br />required by Rule 2.04.7(1). Included in this section of text narrative are brief statements <br />with regard to the impacts due to mining. While Rule 2.04.7(3) requires identification of <br />the extent that the operation may affect surface or underground sources of water put to <br />beneficial use, the detailed discussion of impacts should be quantified and summarized <br />under Rule 2.05.6(3), rather than included with the baseline hydrologic information. <br />Please also modify permit text on page 2.04-11 b indicating the correct reference to the <br />probable hydrologic consequences section (not section 2.04.7). Permit text on 2.04-24 <br />also identifies wells that could be impacted. This type of information should be included <br />and summarized in the PHC section of the permit application. Rule 2.04.7(3) should <br />focus primarily on the alternative water supply available should contamination or <br />diminution occur and water rights owned or leased by the operation. Exhibit 8(4) is <br />inadequate with regard to a summary of all hydrologic impacts that are probable due to <br />the proposed operations. Please review these pages along with Exhibit 8(4) and include <br />a detailed summary of the probable hydrologic consequences of mining to surface and <br />ground water quantity and quality. This summary should address the probable; <br />• Impacts to groundwater quantity (both wells and springs) from subsidence; <br />• Impacts of mining to groundwater quality; <br />• Impacts of mine water inflow and subsequent discharge to surface water quality; <br />• Impacts of subsidence to surface water quantity; and <br />• Impacts of mine water consumption to surface water users