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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />INTEROFFICE MEMORANDUM <br />TO: Jared Ebert <br />FROM: Mike Boulay M 8 <br />DATE: February 2, 2012 <br />SUBJECT: Honeywood Coal Company, Hamilton Mine (Permit No. C -91 -078), <br />SL -3 Application & Hydrology Monitoring Plan Review <br />COLORADO <br />D IV IS I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />Honeywood Coal Company has applied for a full Phase III bond release (SL -3, January 3, 2012) for <br />the Hamilton Mine. Given the pending bond release application SL -3, I was requested to review the <br />approved Water Monitoring Plan to determine compliance with permit conditions. I have reviewed <br />the Hamilton Mine permit application package (PAP), Annual Hydrology Reports (AHRs) and <br />other related documentation with regard to the existing approved Water Monitoring Plan. I have the <br />following comments and concerns that need to be addressed prior to final bond release approval. <br />The Division approved the cessation of all water monitoring with exception of CDPS requirements <br />in July 1999 with TR -7. On page 2.05 -36 of the PAP, Honeywood states "Water monitoring <br />requirements as detailed above will be re- initiated two years prior to the time the Operator requests <br />final bond release." This was not implemented. The last sample data were provided in the 1998 <br />AHR. There has been no sampling and analysis of surface water, groundwater or springs at the <br />mine site since 1998. This is clearly out of compliance with the permit requirement to sample two <br />years prior to final bond release. <br />After reviewing the PAP and related hydrology data I also made some notes regarding the overall <br />groundwater monitoring program for the mine as follows. Well completion information was <br />requested back in July of 1998 and apparently was never provided by the operator. This <br />information is critical to assessing groundwater quantity and quality impacts. Well completion <br />information is unavailable other than a "typical" drawing for an alluvial well and a bedrock well <br />(see Hydrologic Area Map) and the total depth of the wells listed next to the well location for some <br />but not all wells. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines <br />