2011-12-01_APPLICATION CORRESPONDENCE - C2010089 (2)

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Response — The correct table was inadvertently not inserted. Data for Coal Canyon is now included in the revised Table 2.05.6(3) -2. Text is now inserted in support of calculations and information in Table 2.05.6(3) -2. 14. DRMS: There still is insufficient discussion and information pertaining to potential impacts to Coal Canyon. Table 2.05.6(3) -2 has a shaded space provided for Coal Canyon predicted flow and quality but information otherwise provided. Coal Canyon is adjacent to the mining area and should be discussed. Please update Section 2.05.6 -3 with the probable hydrologic consequences to Coal Canyon. Response — The correct table was inadvertently not inserted. Data for Coal Canyon is now included in the revised Table 2.05.6(3) -2. Text is now inserted in support of calculations and information in Table 2.05.6(3) -2. 18. DRMS: Meehan draw has been added to the PHC discussion and analysis. However, there is still no discussion or analysis for Coal Canyon. See items 10 and 14, above. Response —The correct table was inadvertently not inserted. Data for Coal Canyon is now included in the revised Table 2.05.6(3) -2. Text is now inserted in support of calculations and information in Table 2.05.6(3) -2. 21. DRMS: Information for Coal Canyon has not been provided. Please update the PHC accordingly. Response — The correct table was inadvertently not inserted. Data for Coal Canyon is now included in the revised Table 2.05.6(3) -2. Text is now inserted in support of calculations and information in Table 2.05.6(3) -2. 25. DRMS: In the May 26, 2011 submittal, Western Fuels provided the monitoring plan in three tables in Appendix 2.05.6(3) -3. The Division has follow -up questions: a) According to permit text page 6 of Section 2.05.6(3), surface water monitoring site SW- N206 was destroyed and, therefore, does not appear in Table 2 on page 2 of Appendix 2.05.6(3) -3. However, the site still appears on Map 2.04.7 -1. In order to avoid any confusion, please add a note next to the site on the map to show that the site was destroyed and the year it was destroyed. Response — The requested note has been added on Map 2.04.7 -1. The CDPHE receiving stream standards for Segment 12 of the San Miguel River include standards for certain heavy metals that do not appear in the surface water baseline data of Appendix 2.04.7(2) or in the operational monitoring program presented in Table 3 of Appendix 2.05.6(3) -3. These heavy metals include arsenic, boron, cadmium, chromium III, chromium IV, copper, cyanide, mercury, nickel, silver, uranium and zinc. Rule 2.05.6(3)(b)(iv) requires that the operator have a hydrologic monitoring plan in place to determine the impact on the hydrologic balance. Under Rule 2.05.6(3)(b)(iv)(D), the Division can require the monitoring of additional water quality parameters in this hydrologic monitoring plan if warranted by site - specific conditions and for good cause shown. The chemical analyses for overburden, interburden and underburden presented in Appendix Table 2.04.6 -2 show that some of these metals are in the rocks, although chromium, cyanide, nickel and silver were not sampled. The Division believes that, because these heavy metals have receiving stream standards and because these heavy Page 32