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MINE ENGINEERING <br />MINE RECLAMATION <br />August 15, 2012 <br />J. E. STOVER & ASSOCIATES INC. <br />Janet Binns <br />Division of Reclamation, Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Golden Eagle Mine Permit C- 1981 -013 <br />TR -57 Midterm Permit Review <br />Incidental Permit Boundary Revision <br />Dear Ms. Binns <br />2352 NORTH 7 STREET, UNIT B <br />GRAND JUNCTION, COLORADO 81501 <br />PHONE: (970) 245 -4101, FAX 242 -7908 <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />RECEIVED <br />AUG 2 0 2012 <br />Division or reclamation, <br />Mining and Safety <br />On behalf of New Elk Coal Company (NECC), the following responses have been prepared in reply to the <br />Division of Reclamation, Mining and Safety (DRMS)' comments and concerns regarding the above - <br />referenced midterm review document dated April 23, 2012. Changes to the permit pages and maps will <br />be incorporated into the permit by TR -57. <br />1. DRMS - Rule 2.03.4(6). Map 1, Map 2, Attachment 1A, Attachment 1B, Please ensure that the <br />status of surface and mineral ownership is up to date, with all addresses and information correct. <br />NECC - Surface and mineral ownership was updated in section 2.03.4. New Maps 1 and 2 were <br />prepared. <br />2. DRMS - Through Permit Revision PR -02 of CDRMS Permit No. C- 1981 -012, the New Elk Mine <br />assumed responsibility of groundwater monitoring wells NM20, NM21, NM22, NM23, and SF -2. <br />These monitoring wells and information pertaining to these wells are listed in the Golden Eagle <br />Permit on pages 2.05 -47b, 2.05 -47c, and 2.05 -47f. In addition, the transferred wells are identified <br />in the most up -to -date cost estimate, along with well LA -218. Please update the above referenced <br />pages to reflect the transfer of the wells mentioned. In addition, please provide information as to <br />the status of well LA -218. <br />NECC - Revised pages 2.05 -47b and 2.05 -47f are enclosed. A well abandonment report for LA- <br />218 was sent to the DRMS under separate cover. <br />3. DRMS - The small size of the productivity sample plots need to be enlarged to bring the sample <br />methodology into agreement with Rule 4.15.1 1(b)(i). Quadrat size should be a minimum of 0.25 <br />M and large enough to encompass plants of the larger species being sampled. NECC will need to <br />submit a proposed change to the sampling methodology as a technical revision. <br />NECC - The quadrate size was changed on page 2.05 -23. <br />4. DMRS - NECC should evaluate the currently approved vegetation sampling methodology for <br />applicability to the current permit conditions. Please assure that any sample methodology <br />changes meet the requirements of Rule 4.15.11. Division guidelines (Guidelines regarding <br />