2012-04-20_REVISION - C1981012 (2)

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Page 3 of 7 The information must also include chemical analyses for acid - forming materials, including pyrite, marcasite and sulphur content, pursuant to Rule 2.04.6(3)(a)(iii)(D). Please include chemical analyses for the stratum directly above and below each coal seam proposed for mining, pursuant to Rule 2.04.6(3)(a)(iii)(E). Rule 2.04.7/4.05 — Hydrology Description /Hydrologic Balance 9. During the completeness review, the Division notified the Colorado Division of Water Resources (letter dated 24 February 2012) of the proposed increase to the permit boundary at the New Elk Mine and requested their comments. On 20 March 2012 the Colorado Division of Water Resources (DWR) responded to the Division's request (letter attached). This letter was forwarded, via e -mail, to NECC and its consultants on 21 March 2012. The DWR did not provide any specific objections to the proposed mine expansion, provided that NECC work with DWR to obtain all necessary well permits and provided NECC has a water augmentation plan, if necessary. 10. With the proposed permit boundary expansion and mine plan change, NECC is planning to affect an additional 2,942.8 acres. However, NECC has not provided any updated groundwater or surface water information in the materials provided with PR -04, including baseline water information. Pursuant to Rule 2.04.7(1), please provide the groundwater information listed in the Rule for the permit expansion area to the Division for review. Pursuant to Rule 2.04.7(2), please provide surface water information listed in the Rule for the permit expansion area to the Division for review. 11. Exhibit 8(4) and Permit pages 2.05 -58 through 2.05 -90a contain the Probable Hydrologic Consequences (PHC) for the New Elk Mine. It was last updated in April 2011 with Technical Revision 56. The PHC, however, is only for the Allen and Apache Seams. With PR -04 NECC is planning not only to change the mine plan in the Allen and Apache Seams but also to do extensive mining in the Blue Seam. Please update the PHC section of the permit to include the new mining in the Allen and Apache coal seams and to include the extensive mining planned in the Blue Seam. 12. In questions 7 and 8 above, the Division has asked NECC to provide updated information regarding the groundwater and surface water hydrology and the PHC for the new permit area proposed at the New Elk Mine. To that end, the Division did not see that any new groundwater (deep or alluvial) monitoring wells or surface water monitoring locations were being proposed and that the hydrologic monitoring plan has not been updated. Please review the groundwater and surface water monitoring plans, beginning on Permit page 2.05 -90a, and update these plans as necessary to ensure they are adequate to assess the mining related impacts of the new mine plan. 13. Beginning on Permit page 2.05 -93 of the text, beginning on page 42 -12 (Table 42) of Exhibit 42 and on the Map 20 series, NECC provides information regarding the structure inventory for the permit area of the New Elk Mine. Please indicate if this information includes any wells which are currently inactive or abandoned. Additionally, pursuant to Rule 2.04.7(0, please provide the map coordinates of each well (oil, gas and water) and its depth within the permit and adjacent area. Finally, please include the ownership of each well in the table or description. New Elk Mine PR -04 PAR Letter 3 20 April 2012