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T. Bird, GCC Energy, LLC I8 Jun 2014 <br />C- 1981 -035 f TR -22 / AdegReview Page 2 of 3 <br />Appendix 3(3), Cultural Resource Survey completed by SWCA <br />2. Tab 4 - Geological and Hydrologic Data <br />Appendix 4(4), Drill Site Location, Topography, Abandonment, and Site Drawings <br />3. Tab 8 — Fish and Wildlife Information <br />Appendix 8(5), Natural Resource Survey completed by SWCA <br />The Table of Contents and various sections permit text are also proposed for revision to reflect <br />the addition of the new Appendices and to direct the reader to the pertinent information. <br />Adequacy Comments <br />2.03.5 — Compliance Information <br />1. The last paragraph, regarding abatement of CV- 2022 -003, was removed from Page 1. It <br />would be helpful to add a sentence indicating that the NOV was Terminated on <br />December 11, 2012. <br />2.04.6 — Geology Description <br />2. A new subsection, "Exploration Core Drilling" has been added, beginning on Page 6. <br />The text does not address the question of whether any water- bearing strata may be <br />encountered in the 9 proposed drill holes. In the "Coal Geology" subsection of the <br />approved permit, on Page 5, the text refers to exploration drilling and analysis that was <br />conducted for King 11. The Division was not able to locate information on the location of <br />any previous exploration holes. Were they within the DRMS Permit Boundary? How <br />deep were they drilled? Was any water encountered? Please expand this section to <br />include a discussion of previous drilling programs in the King II area. <br />3. The proposed text and the diagram provided in new Appendix 4(4) refer to the <br />construction of a "cutting pit" at each proposed drill site. Please enhance the detail to <br />include proposed dimensions for the pit(s). Will the size and construction (unlined or <br />lined) vary depending upon the drilling method used (air, air with water injection, or <br />water)? <br />4. For sealing the drill holes, the text states that a cement plug will be used from 10 feet <br />below the surface to within 3 feet of the surface. However, the detail in Appendix 4(4) <br />also shows a cement plug being used where the drill hole passes through the coal seam. <br />Please revise the text and/or diagram so they are consistent. <br />2.115.3(5) — Topsoil <br />5. The application does not address how topsoil will be handled within the areas of new <br />disturbance. Please provide a discussion of topsoil removal / replacement, particularly in <br />areas where the ground will be disturbed for construction of the cutting pits, in <br />accordance with Rule 2.05.3(5). <br />