2012-08-08_HYDROLOGY - C2010088

• Permit No: C2010088
• IBM Index Class Name: Hydrology
• Doc Date: 8/8/2012
• Doc Name: Request for Relief from Water Monitoring Requirements ‎(Memo)‎
• From: Mike Boulay
• To: Sandy Brown
• Permit Index Doc Type: Correspondence
• Email Name: MPB
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
TO: Sandra Brown
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
INTEROFFICE MEMORANDUM Mike King
Executive Director
Loretta E. Pineda
Director
FROM: Mike Boulay / ° B
DATE: August 8, 2012
SUBJECT: Fruita Loadout (Permit No. C- 2010 -088)
CAM - Colorado, LLC (CAM) Request for Relief from Water Monitoring
As you are aware construction at the Fruita Loadout has been delayed. In a letter from J. E. Stover
& Associates dated July 31, 2012 CAM is requesting temporary relief from the permit water
monitoring requirements at the Fruita Loadout. They are proposing to reinitiate water monitoring
one year before the loadout is operational and would submit a technical revision for approval to
modify the permit to temporarily suspend monitoring. As stated in the request letter, the loadout
will be constructed after the McClane Canyon Mine obtains a coal sales contract. The McClane
Canyon Mine is not expected to acquire a coal sales contract in the foreseeable future. For this
reason the construction of the loadout may be delayed for many years.
CAM submitted a data package in the July 31, 2012 letter with all baseline monitoring data
collected to date. I have attached the letter (without the monitoring data) for your review. I have
reviewed the submittal and find that they have sufficient baseline data to meet the requirements of
Rule 2.04.7. They have collected baseline data according to the permit requirements for ten
quarters or 2 Yz years.
I propose that we accept their request and allow them to submit a technical revision to modify the
approved monitoring plan to suspend surface and groundwater monitoring until one year prior to
construction of the loadout. I have reviewed the applicable Rules including 4.05.13 Surface and
Groundwater Monitoring and 4.05.13(3) Monitoring Liability Period. The intent of these rules is
to use surface and groundwater monitoring data to demonstrate that the operation has minimized
disturbance to the hydrologic balance in the permit and adjacent areas; that the operation has
prevented material damage to the hydrologic balance outside the permit area; and that the water
rights of other users have been protected or replaced. Based on this demonstration, the operator
may request reduction or deletion of the monitoring program or control system.
CAM is not requesting a reduction or deletion but a suspension of baseline data collection until
such time that the loadout would be built. Since there is no disturbance at the site and may not be
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