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<br />-4- <br />Overburden Sample No. 1 was classified as a shale with some amount of <br />carbonaceous shale, yet the grain size analysis in Table 2 indicated <br />that 60% of this sample is sand. A shale by definition is a laminated <br />sediment composed primarily of clay or silt sized particles. <br />Overburden Sample No. 2 was classified as a sandstone, yet the grain <br />size analysis indicated almost equal amounts of sand, silt and clay. <br />The roof sample was classified as a shale with small amounts of <br />interbedded coal or carbonaceous shale, yet the grain size analysis <br />indicated that the grain size test could not be run due to large <br />amounts of coal. This should be corrected in the permit application. <br />9. Section 4.05.8 of the permit application states that there are no <br />potential acid-forming or toxic-forming overburden present. This is <br />not correct, see comment 7 under Section 2.04.6 above, this section <br />should be revised when addressing the above referenced comment. <br />Hydrology Description - Rule 2.04.7 <br />Both the ground and surface water sections of the permit application do <br />not adequately address the requirements of Rule 2.04.7. The applicant <br />should review this section of the regulations and revise this section <br />of the permit application. Following are specific concerns related to <br />this section. <br />Groundwater <br />1. Potential aquifers within the proposed permit and adjacent area are not <br />identified in this section. This should be addressed including a <br />discussion of recharge, storage and discharge characteristics. <br />2. Known uses of the water in the aquifers and water tables have not been <br />identified and discussed although several wells are located on Map 7. <br />3. The quality of subsurface water in all wells should be presented if <br />available. Water availability in these wells should also be addressed. <br />4. This section needs more detail and evidence of the lack of subsurface <br />water. There is no factual evidence presented that there is indeed a <br />lack of groundwater in the proposed permit area. See Comment 4 under <br />subsection 2.04.6. <br />5. When was the mapping of springs and seeps accomplished? Have any <br />surveys for springs and seeps been done during spring runoff? <br />6. Page 4.05-8 Section 4.05.11 states that no discussion of groundwater <br />protection is necessary because of lack of groundwater and lack of the <br />presence of acid-forming and toxic-forming substances. As mentioned <br />previously these areas need to be re-evaluated and this section may <br />need to be revised. <br />