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Peabody <br />Twentymile Coal <br />_CVV <br />JUN p ? 1p10 <br />iann, <br />U1V1?Gj? U1 <br />29515 Routt County. Road 27 <br />Oak Creek, CO 80467•-: <br />970.879.3800 <br />Mr. Jason Musick, Environmental Protection Specialist May 31, 2010 <br />Division of Reclamation, Mining, and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />(303) 866-3567 X 8134 <br />RE: Twentymile Coal Company - Foidel Creek Mine (Permit No. C-82-056), Minor Revision <br />(MR10-243) - Replacement Thickener Underflow Borehole <br />Dear Mr. Musick: <br />Twentymile Coal, LLC (TC) requests CDRMS approval of a Minor Revision to our existing approved <br />Permit for installation, operation, and reclamation of a replacement Thickener Underflow Borehole. <br />The replacement Thickener Underflow Borehole will replace the previously constructed borehole <br />(refer to TR07-60), which recently plugged, and could not be rehabilitated. Similar to the existing <br />Thickener Underflow Borehole, the replacement borehole will convey the thickener underflow slurry <br />from the Washplant Thickener(s) through a nominal 14.75-inch O.D.. cased and grouted borehole <br />approximately 310 feet deep, which will carry the slurry to abandoned and sealed underground mine <br />workings in the Southwest Mining District, consistent with existing approved practices. <br />The replacement borehole will be drilled adjacent to the existing Thickener Underflow Borehole, from <br />the existing pad, and is not expected to involve any additional surface disturbance. The north end of <br />the existing Thickener Underflow Pipeline will be partially excavated, shifted to the west, and <br />extended to connect to the replacement borehole. <br />Given our experience with the recent Thickener Underflow Borehole blockage and minor coal slurry <br />discharge, we propose to implement additional safeguards to both prevent, and contain a coal slurry <br />discharge, should one occur. Borehole drilling and completion methods will be essential the same as <br />used for the previously constructed Thickener Underflow Borehole, except that either high-strength, <br />corrosion/abrasion-resistant casing or a wear liner will be used. We also propose to install a float <br />sensor in the manhole for the each thickener underflow borehole to detect any significant liquid <br />accumulation at the wellhead, to cap any inspection/monitoring pipes to prevent leakage under <br />pressure from any fluid that may escape to the secondary containment pipe, to provide a means for <br />controlled discharge and containment of any fluid accumulations, and to implement regular borehole <br />and pipeline inspections. We will continue to utilize differential pressure gauges at either end of the <br />pipelines, double-walled pipe, and moisture sensors, to provide for timel'.y detection of any leakage or <br />pipeline breach, and to protect against any potential leakage or spills. Pump controls and shut-off <br />valves, controlled from a central monitoring and control center, will allow the slurry flow to be cut-off, <br />and the pipelines drained, if necessary for maintenance and repairs. <br />r <br />While the associated disturbance areas will essentially be reclaimed within a reasonable time period <br />following pipeline installation, TC does not consider these areas to be reclaimed for purposes of <br />reporting, since there is some potential that they may be re-disturbed for pipeline repair or maintenance