2012-11-09_REVISION - C1981019 (2)

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COAL 8 COMPANY •AEOPj,E•PRODUCTIO� parameters met water quality standards and did not contribute additional pollutants to receiving streams. Storm and melting events tend to show slightly elevated levels of TSS and Total Recoverable Iron, but these elevated levels are at or below the levels that can be found in the receiving streams and are directly related to a precipitation event. Furthermore, this data verifies that Colowyo has historically met NPDES discharge standards and is not contributing pollutants of concern to receiving streams. Therefore, Colowyo is demonstrating through this data that surface water and shallow groundwater degradation is not occurring within the receiving streams. Note: NPDES discharge data was not included in this response as the Division is provided with this information quarterly through Discharge Monitoring Reports, as provided to the Colorado Department of Public Health and Environment. Overburden suitably analyses, dating back to 1983 are presented in the Annual Reclamation Report (ARR). The results of this monitoring also support the Division's pervious determination that Colowyo backfill material is benign in chemical nature. The backfill material does not exhibit a significant risk for forming or precipitating toxic materials or pollutants of concern. Please see Section 2.05.3 — Overburden Monitoring Program for a more detailed demonstration of this point. This lack of pollutants in the backfill material is another indicator that mining impacts on subsurface water should be exceptionally minimal and is an additional justification that points of compliance are not needed. All the justifications provided above have also been agreed upon by the Division in the Proposed Decision and Findings of Compliance document provided under SL -05 on July 25, 2012. Under the requirements for Phase/// bond release the Division is required to evaluate the Hydrologic Impacts as required by Rule 3.03.2(2). As the Division is aware, this evaluation must consider whether the mining and reclamation impacts have contributed pollution to the surface or subsurface water in the vicinity of the bond release area. Within the Hydrologic Impacts section of the Proposed Decision document for SL -05, the Division addressed the New Good Springs Well as an alluvial well located down gradient of the mine. The Division noted that TDS levels where slightly elevated which concurs with Colowyo's Probably Hydrologic Consequences in the PAP. The Division also stated that there never has been a significant possibly of groundwater contamination from the West Pit, and there is not any indication that it has transpired. Additionally, the A Western Fuels - Colorado, LLC mining property