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<br />PQabody <br />Twentymile Coal Company <br />January 17, 2005 <br />Mr. Byron Walker <br />Environmental Protection Specialist <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />(303)866-4941 <br />29515 Routt County Roatl #27 <br />Oak Creek CO 80487 <br />970.879.3800 <br />RECEIVED <br />JAN 2 p 2005 <br />Divisiwr of Minerals & Geology <br />RE: Foidel Creek Mine (Permit No. C-82-056) -Revisions to Clarify, Update, and Supplement <br />Existing Permit Information for Specific Historic Disturbance Areas, Haul Roads, and <br />Existing Water Storage Features <br />Deaz Mr. Walker: <br />As a result of your observations during several recent inspections, our review of the Twentymile Coal <br />Company (TCC) operations and permits, and our related ongoing mutual discussions, several issues have <br />been identified where clarification, updating, and supplemental information is needed to assure that permit <br />documentation accurately reflects current "on-the-ground" conditions and activities. In some cases, this <br />need arises from problems in consolidating or cross-referencing information from the previous CYCC <br />Permit, or from the evolution of more stringent interpretations of specific regulatory requirements. <br />The identified issues of concern were accurately identified and summarized in your recent December 2004 <br />Inspection Report. Attached is a summary response outlining our approach for timely resolution of the <br />identified issues. Our responses are provided in a comment/response format to facilitate your review. <br />In most cases, we have fully completed the outlined resolution measures, and the corresponding Permit <br />Application Package (PAP) documentation accompanies these responses. The supporting PAP <br />documentation is being submitted in the form of three separate Technical Revisions and one Minor <br />Revision, as follows: <br />1) Technical Revision for Alternative Sediment Control Measures and/or Small Area Exemptions for <br />the Scoria Storage Area, Former CYCC Office Area, and "Trudy's Comer" azea <br />2) Technical Revision to Clarify and Update Delineation of Active Mine Haul Roads <br />3) Technical Revision to Re-designate Existing Water Storage Features as Mine Impoundments <br />4) Minor Revision to Modify Mine Facility Designations and Disturbance Boundary <br />Each revision has been formatted as a stand-alone package with revision application form and <br />corresponding PAP revision materials. The attached Summary of Revisions/Additions identifies the revised <br />materials for each of the individual revision packages. As identified in our responses, there aze specific <br />additional documentation items that we are working diligently to complete, which will be forwazded to you <br />for review within the timeframes specified. <br />