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Northfield Response: permit text has been revised to clarify methods and statistical <br />demonstrations. <br />DRMS Response: NP has provided a good discussion of sampling methods and <br />statistical demonstrations required by Rule 4.15.11 in Exhibit J. As discussed above, a <br />summary of the methods and successful statistical demonstrations should be <br />included in Section 2.05.4 of the permit with reference to Exhibit J. <br />32. NP is proposing to generate approximately 10,000 cubic yards of underground <br />development waste (coal mine waste) during construction of the portal face-up area. This <br />material is proposed to be incorporated as part of the mine bench and then regraded into <br />the post-mining topography upon completion of mining. Please explain how the placement <br />of this material in the portal bench and handling during reclamation will comply with Rule <br />4.10.1(1) for coal mine waste banks. <br />Northfield Response: Portal development material to be part of mine bench. Testing is <br />forthcoming. <br />DRMS response: Please submit this information when available. Please correct the typo on <br />page 2.05.3-31 "ling". <br />Northfield Response: Typo was corrected and sampling data is included as Exhibit AI and <br />permit text is updated on pages 2.05.3-30 and 31. <br />DRMS Response: Response accepted. <br />Rule 2.05 Operations and Reclamation Plan <br />34. Please submit a hydrologic monitoring plan for the operational and post-operational <br />period for the proposed mine. Monitoring locations, frequencies, and sampling parameters <br />should be clearly presented in tables and/or permit text for both surface and ground water. <br />Sampling of the proposed mine water discharge prior to entering the sediment pond is also <br />required and should be considered part of the overall hydrologic monitoring program. <br />Monitoring of mine inflow should also be conducted on a periodic basis and calculations <br />regarding mine water consumptive use would be appropriate to include annually in the <br />hydrologic report. Please add a commitment on page 2.05.6-5 for a submittal date of the <br />annual hydrology report each year. <br />Northfield Response: Hydrologic monitoring plan is in Exhibit AB. <br />DRMS response: The use of Table Value Standazds may be necessary at some point during <br />the monitoring. Hazdness is necessary to calculate the standazd that applies to the particular <br />sample. Please include hazdness in Table 1 and Table 2. Also, please identify the tables in <br />the title regading their applicability to surface or ground water. <br />The plan proposes to monitor eight private wells in and azound the mine permit area <br />