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2013-07-29_GENERAL DOCUMENTS - C2009087
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2013-07-29_GENERAL DOCUMENTS - C2009087
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Last modified
8/24/2016 5:22:59 PM
Creation date
7/31/2013 8:54:29 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2009087
IBM Index Class Name
General Documents
Doc Date
7/29/2013
Doc Name
Modifying Discharge Point of Compliance for Selenium
From
Brownstein Hyatt Farber Scheck
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
JDM
DIH
Media Type
D
Archive
No
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Indeed, the Mine Permit issued for Sage Creek repeatedly emphasizes the goal of <br />protecting surface and groundwater outside of the Mine Permit boundary. In issuing the Permit, <br />the DRMS found that "the assessment of the probable cumulative impact the assessment of <br />probable cumulative impact of all anticipated mining in the area on the hydrologic balance <br />specified in section 34- 33- 110(2)(1) has been made by the Division and the proposed operation <br />thereof has been designed to prevent material damage to hydrologic balance outside the permit <br />area." Mine Permit - Section III(c). The Division also found that the proposed operation would <br />not "interrupt, discontinue, or preclude farming on alluvial valley floors that are irrigated or <br />naturally subirrigated .... or materially damage the quantity or quality of surface water or <br />groundwater systems that supply [these] alluvial floors." Mine Permit — Section III(e)(1)(A),(B). <br />These findings regarding potential impacts outside the Mine Permit area are reflected in <br />the Permit's terms and conditions. Peabody must conduct its surface coal mining and reclamation <br />operations only on those lands that are specifically designated within the permit area in its <br />application and not beyond the Mine Permit boundary. Mining Permit — Section IV.C.7. With <br />respect to environmental protection, including water quality protection, Peabody must conduct its <br />operations as necessary to prevent significant environmental harm to the health or safety of the <br />public. Mine Permit — Section IV.C.2, IV.C.4(a). There is nothing in the Mine Permit that <br />contradicts Peabody's request to move its discharge point of compliance for selenium from the <br />Ponds' outfalls to outfalls below the adjacent wetland. <br />In summary, the Mine Permit and applicable federal and state law repeatedly emphasize <br />the importance of the protection of surface and groundwater outside of the Mine Permit area. <br />Peabody's request to move the selenium discharge compliance points to take advantage of on -site <br />treatment systems is fully consistent with this goal. Certainly, nothing in the Mine Permit or the <br />applicable law suggests that such a request should not be granted. <br />hydrologic balance outside the permit area." 30 U.S.C.A. § 1260(b)(3). Thus, as with the Colorado Mining Act, the <br />approval of the mine permit, solely addresses waters and the hydrology outside the permit area. <br />
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