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C~ <br />J <br />that the 6.4 acres to be disturbed are an insignificant part <br />of the AVF farming unit." <br />SRM Response: <br />Based on the most recent available information provided by the <br />Agriculture Economics Division of the USDA, the value of hay from <br />an irrigated hayland is about $70/ton. (Storm Ring owns the hay <br />and values it at $58/ton). The reported yield from the Storm <br />Ring Property is about 3 tons per acre (average of 1982 and <br />1983). Therefore, the economic value of this land from a <br />production point of view is between $174/acre and $210/acre or a <br />total of $20,010 to $24,150 for 115 acres. Reducing the farming <br />unit by 6.4 acres will result in an economic reduction of $1114 <br />to $1344 or 5.68 of predicted production. <br />MLR Comment: <br />"3) The applicant must submit a quantitative assessment of <br />the effects of the coal refuse embankment on the quantity and <br />quality of surface and ground water supplying the AVF <br />downgradient from the pile. No assessment is contained in <br />the application." <br />SKDI Response: <br />An analysis of the proposed coal refuse embankment by Chen and <br />Associates concluded that about 50 gallons per minute (GPM) would <br />seep from the impoundment. By using a flow net analysis, they <br />also concluded that the seepage collection pond would intercept <br />nearly all impoundment seepage. The groundwater table in the <br />bedrock and overlying surficial material is relatively shallow <br />and subparallel to the topography. However, the water table is <br />at the surface in the vicinity of SP-3, maintaining intermittant <br />stream flow. <br />Regardless of the actual seepage value, whether it be 5 or 500 <br />GPM, a mound would be expected to develop on the existing shallow <br />water table, resulting in more water discharge in the form of <br />springs and seeps. Since the proposed seepage collection pond <br />will be keyed into the bedrock, all surface water and a <br />significant amount of shallow groundwater will be intercepted by <br />the pond. This water will be pumped back to the impoundment for <br />use in the hydraulic mine cycle. <br />The relatively low permeability and the directional nature of the <br />permeability restricts the amount of groundwater flow from this <br />drainage to the unconsolidated sediments of the AVF. If a <br />cross-sectional area of 100 square feet, a permeability of 10E-5 <br />cm/sec, and a gradient of .17 (measured on Figure 3.3-17) are <br />