2013-01-22_REVISION - C1981019 (3)

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COAL COMPANY 04 • � Op LS • PSODDC[1011 •� The Division has also previously approved text in Colowyo 's PAP which addresses Rule 4.09.1(7). In Exhibit 21, Item 1, Addendum No. 3 -5, Shannon & Wilson 's report addresses a FS for a permanent fill in the conclusions section and it states, "The Colorado Mined Land Reclamation Board regulations (2005) require a long term FS of 1.5 or greater for permanent spoil fill slopes; they do not specifically address temporary slopes." This statement by a professional engineer and approved by the Division previously sets precedence that the Division agrees that the rules do not address a FS for a temporary spoil pile. In conclusion, Colowyo firmly believes it is meeting all the requirements of the Colorado Mine Land Reclamation Board regulations with the FS that is presented in Addendum 4 of Shannon & Wilson 's report. Additionally, because the rules do not specifically address a FS for a temporary spoil pile, Colowyo feels that a certified professional engineering report presents the best alternative to calculating a FS utilizing current professional judgment and previously approved materials, because the rules do not specifically address an FS for a temporary spoil pile. • Shannon &Wilson's analysis does not address the fact that some of the proposed excess spoil would overlay an area of highwall mining. Please address the potential impact of the additional load from the proposed excess spoil fill on the excavated sections from highwall mining as well as the integrity of the proposed excess spoil fill. Response: In Exhibit 21, Item 1, Addendum No. 3 -6, potential highwall mining impacts have been presented and approved by the Division previously. Colowyo believes this section of the report addressing highwall mining in the vicinity of the proposed spoil pile adequately addresses potential impacts from previously performed highwall mining below the permanent West Taylor Fill. • Please add information to the appropriate text and to Map 45 showing how drainage from the temporary spoil pile will drain to the pit. Response: Per Rule 4.05.2(1), "All surface drainage from the disturbed area is required to be routed through a sedimentation pond or a series of sedimentation ponds, or other treatment facilities before leaving the permit area." Therefore, should Colowyo desire to retain drainage from the temporary spoil pile in pit there are no requirements for Colowyo to A Western Fuels - Colorado, LLC raining property