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''WWC ENGINEERING <br />August 22, 2011 <br />Permit C- 1980 -001 <br />Janet Binns <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street <br />Room 215 <br />Denver, Colorado 80203 -2273 <br />611 Skyline Road - Laramie, Wy 82070 - (307) 742 -0031 <br />FAX (307) 721 -2913 - E -mail: infolar @wwcengineering.com <br />RE: Edna Mine, Permit C -1980 -001, SL -11 Bond Release, CDRMS Coal Inspection Report, <br />First Round Comment Response <br />Dear Janet: <br />This letter presents First Round Comment Response to the Colorado Division of Reclamation, <br />Mining and Safety's (CDRMS) Coal Inspection Report (Report) for Bond Release SL -11 for the <br />Chevron Mining Inc. (CMI) Edna Mine, Permit No. C- 1980 -001 (Permit) and verbal <br />communication with Janet Binns of CDRMS on August 12, 2011. The First Round Comments <br />were presented in CDRMS Report from Janet Binns on July 7, 2011. This response pertains to <br />Bond Release Application SL -11 (West Ridge Area, Moffat Area and Support Facilities Area) <br />for Phase II and III submitted on May 13, 2009 to CDRMS by WWC Engineering (WWC) on <br />behalf of CMI. The partial Reclamation Bond Release Inspection (Inspection) performed on <br />June 21, 2011 was the third Inspection with previous inspections performed on July 20, 2009 and <br />August 24, 2009. CDRMS Comments are reproduced below for clarity. CMI responses are in <br />italicized text below the pertinent comment. <br />CDRMS Comments <br />1. ROADS <br />Four roads remain as permanent roads throughout the remaining permit area: 1) North <br />Road, 2) Skyline Road, 3) West Ridge Road and 4) Lower Moffat Road. Overall the <br />roads remain in good to fair conditions. The North Road exhibited some rilling from <br />runoff this spring. The rilled location is immediately south of the intersection with the <br />Lower Moffat Road. The extent of the damage is from approximately C -5 location of <br />Exhibit 3.5 -7 (Sheet 2 of 2), to Culvert E -1. The length of the damaged area is <br />approximately 60 yards. The deepest rilling is approximately 4 inches deep. <br />The downslope culvert from this drainage, El, remains clear. The ditch upslope from the <br />road remains intact and clear of any blockage. This past winter saw record levels of <br />snowfall. The Yampa River Basin reported 266% of average snowpack. The melt -off <br />was very late, and the Division recorded snow still on the mine property in late May. <br />Based on the rilling patterns of runoff across the North Road, we suspect that a snowdrift <br />or ice dam temporarily blocked the ditch. This would cause the runoff from the ditch to <br />