2011-06-20_PERMIT FILE - C1982056

• Permit No: C1982056A
• IBM Index Class Name: Permit File
• Doc Date: 6/20/2011
• Section_Exhibit Name: 2.06 Special Categories of Mining
• Media Type: D
• Archive: Yes

Table 72 B, NMD Recharge Time Estimate, provides the number of days it would take to fill in the additional
fracture volume resulting from subsiding the bedrock. Again, it should be recognized that this is a very
conservative estimate, due to the character of the stream. The data presented assumes that sandstone bedrock
can be found along the entire length of Fish Creek overlying the panels, and this is not the case. The section in
which the sandstone unit is exposed is the approximate 1,260 feet of channel in Section 10, T5N, R86W. The
remainder of the channel is alluvial material overlying the Lewis Shale. Given the nature of the shale, it will
swell to fill -in any cracks that may occur. The amount of time necessary to fill -in the additional fracture
volume varies from 0.6 days to 17.4 days for Panel 13- Right, depending on the time of year mining and
subsequent subsidence occurs. For Panel 14- Right, the amount of time required to fill the fracture volume
varies from 0.3 to 7.9 days, Panel 15 -Right varies from 0.2 to 6.2 days, and Panel 16 -Right varies from 0.2 to
6.8 days.
TCC is the immediate downstream user of irrigation water, and does not foresee any impacts to its agricultural
operations due to any potential loss of water from the system. In the event that significant losses occur during
the irrigation season, TCC has sufficient water rights under its approved Augmentation Plan to augment any
loss. In reference to water quality impacts, the ongoing downstream monitoring at Station 900 on Foidel Creek
does not show any changes that can be attributed to subsidence over Panels 8- and 9- Right. Refer to TCC's
1996, 1997, and 1998 Annual Hydrology Reports for relevant data. Table 37A, Foidel Creek Flow Analysis
after Subsidence in the EMD, shows that water is not being lost to segments of Foidel Creek that have been
undermined and subsided in the EMD. This is based on comparing Site 800 plus ponds to Site 900. The Site 8
data is not being used in the comparison, due to the discrepancy in the data for Site 800 and Ponds B, D, E, F,
and G. The total flow from Site 800 plus the ponds should approximate the flow recorded at Site 8. TCC is
investigating the discrepancy and will make changes to Site 8 as needed.
In order to validate that no impacts will be realized to AVF areas downstream of its operations, TCC will
continue to monitor the current downstream surface and alluvial water monitoring stations. These stations are
presented on Map 13A, Hydrologic Monitoring Program. The stations will be monitored consistent with the
• existing monitoring schedule. These stations are located along Fish Creek in Section 5, T5N, R86W. In
addition to the current hydrologic monitoring program, TCC will initiate a program directed at the segment of
Fish Creek to be impacted by mining in the NMD. This environmental program is presented in Exhibit 4e -7,
NMD- Fish Creek AVF Monitoring Program. The program includes the following components: hydrologic
monitoring, vegetation monitoring, and subsidence surveying.
NMD and WMD (17 through 21 Right, and 13- through 16 -Left: PRO3 -06 and PRO9 -08)
TCC's mining operation will result in subsiding portions of Fish Creek and its associated AVF. Potential
impacts to the associated ranches are described in the following paragraphs. The ranches are shown on Map 1B.
Given the fact that the valley floor will subside, parts of the area will be flooded. TCC is not proposing any
reclamation activities for the flooded areas. The extent of flooding and loss of acreage is described in the
following paragraphs. The extent of flooding is controlled by the elevation overlying the gateroads and bank
height immediately upstream from that point. In reference to subsidence impacts to Fish Creek, TCC submits
that its mining operations will not impact enough of the valley floor to be significant to the existing Camilletti &
Sons, State of Colorado, or Cross - Mountain Ranch ranching operations. The valley floor is used exclusively as
rangeland, and is not currently flood - irrigated for cropping.
There are no established irrigation ditches along Fish Creek which irrigate designated AVF areas within the
limits of Longwall Panels 17- and 18 -Right or Panels 13- through 16 -Left. This reflects the fact that it is not
economically feasible to establish an irrigation system for the limited alluvial areas along the margins of the
meandering Fish Creek. Given the extensive irrigation systems established for other nearby lands when the
surrounding area was originally settled and developed, it is reasonable to conclude that this segment of Fish
Creek is not conducive to flood irrigation. The alternate to flood - irrigation is the utility of sub - irrigation to
• enhance crop production. Potential for effective sub - irrigation, depends on depth of rooting of selected species
and water -table elevation during the growing season. Data previously collected by P & M indicate that there are
restricted areas in which sub - irrigation does occur. The extent of sub - irrigation, based on vegetation type, was
verified during the 1997 growing season by vegetation production studies within the defined Fish Creek AVF.
PRO9 -08 2.06 -25.4 04/29/09