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Brock Bowles, Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />RE: Keenesburg Mine — Permit No. C -1981 -028 <br />Technical Revision 43 (TR -43) <br />Adequacy Review #1 -- Response <br />Dear Mr. Bowles: <br />ENERGY COMPANY <br />P.O. BOX 467 GOLDEN, COLORADO 80402 <br />December 19, 2012 <br />RECE <br />DEC . 312 <br />Division of Reclamation, <br />Mining & Safety <br />Coors Energy Company (CEC) is submitting responses and explanations addressing the <br />comments received in your December 12, 2012 Adequacy Review #1 letter for Technical <br />Revision 43. For clarity the comment is reiterated with the response following. <br />1) The first paragraph on page 116 of the permit needs to be revised to include a citation that the <br />predictive equations were subsequently updated with TR43. This will provide clarity to future <br />reviewers. <br />CEC has prepared a revised page 116 that includes text describing that the predictive equations <br />now proposed were revised by TR43. The revised page 116 is attached (3 copies). <br />2) Based on the Division's calculations, it appears the precipitation amount from September of <br />1994 to July of 1995 should be 16.59 inches instead of the 16.77 inches as indicated in the <br />revision. Coors Energy Company reported the precipitation amount for September of 1994 to be <br />.81 inches according to the 1994 Annual Hydrology Report. However, the revision indicates the <br />precipitation for this month was .99 inches. This appears to be the source of the discrepancy. <br />This precipitation value modifies the predictive equations slightly and should be revised and the <br />equations updated. <br />On November 29, 2012 Danny Kipp and Michael Savage checked the precipitation records at the <br />mine. The spreadsheet maintained at the mine with the master record of precipitation from 1984 <br />to date shows 0.99" of precipitation for September 1994. Further investigation by Danny, <br />Michael and I found the discrepancy to be in the 1994 AHR precipitation table where the author <br />reported the precipitation amount as 0.81 ". Since the predictive equations were derived using <br />