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<br />' St ulati on No~ sho uld include a description • any non-complying ,
<br />xisting struct re s, or remove the reference if they do not exist. ~/j/~
<br />J
<br />~/,W,A' 11 U R/1~ a .~ Mr,,f, i.+ UO(, 7 7 ~j~.:a 3 1.rw F~~ ~a: ~ iN ~y w ~ r.,) J.' C / y
<br />A ~I} w coa l ownership map should be provided which clearly describes the
<br />gtOposed permit area and the corre ct location of the Federal coal.
<br />hemdiscussion on page 8 concerning the load-out should be revised to
<br />dicate that the facility will be returned to its pre-mining use as an
<br />ndustrial site.
<br />In paragraph 3 of the Legal, Financial and Compliance Information
<br />section, the discussion should be amended to indicate that all notices of
<br />~ violation have been resolved. ~/
<br />r' .ry
<br />(S,-~~"B 5 The geolo escription presented on page ~2~should describe the dip,
<br />{~~,. ,n ~' ~ strike, epth and thicknes~ of the coal seams proposed to be mined.
<br />/CO. /""' /"~ ~L Y. ,a N, Vcfu..z ~rf co:.l .RaN~ Cv:4~~~'s j
<br />/ The information in paragraph 1, page 12 of the draft findings document
<br />Sy discusses fhe chemical analysis of the roof and floor material associated
<br />l~~f'' with the "E" seam. A similar discussion should be presented for the "D"
<br />.JD ~kk~ seam.
<br />Further, the narrative on pages 67-69 of Vol. 10 of the permit
<br />application as referenced on page 12 does not adequately address analysis
<br />~~-7(„of roof and floor material associated with the coal seams as well as
<br />/~~~'~,analysis of the s ams. The holes sampled and analyzed are not adequate
<br />` in that only the ~' seam and associated roof and floor material were ~~~,,
<br />V d~~,Y sampled. In addition, the holes sampled are too close to the coal `' J,e,(,w
<br />~,~ outcrop- sT-•.< `~" sue'"', ,~o+ !i^c Lloce ado Cc;~P U~,~,wPCp~•..
<br />~ ~ ,~
<br />~~~
<br />' t is imperative to sample for SAR, pyrite, sulfur and total sulfur from
<br />k, locations that are representative of the coals to be mined. This is
<br />y,n'~ necessa because of the poor quality water discharging from the old
<br />US .5/ ~ works s. If the Division is in possession of additional information,
<br />~'' not n OSM's files which adds insight to the above concerns it should be
<br />pr vided.
<br />°The discussion presented on page 12, paragraph 3, concerning the refuse
<br />area should be revised to clearly state that the 20 acre refuse area is
<br />composed of a 12 acre waste pile and an 8 acre overburden pile. The
<br />discusion on page 32 with respect to topsoil replacement at the refuse
<br />sits should be clarified in a similar manner.
<br />,8. The discussion presented on page 13, paragraph 1, concerning the existing
<br />sediment control system should be revised to clearly state the rationale
<br />for acceptance of a sediment control system designed and approved under
<br />the interim regulations.
<br />`'9. The Division should clarify and/or stipulate what the operator will be
<br />~y,,,q ~~ a required to implement with respect to the small area exemption discussed
<br />~ on pages 14 sad 15 and the reasons why the applicant's proposal is
<br />-~. S accepta~b~~~eeT
<br />~~•~ 5~~~,(y t ruaJTT•?
<br />~,y,,.,~ 0. he ground water information presented under Part VI of page 15 discusses
<br />the Division's refined ground water monitoring plan. The Division should
<br />stipulate that the operator will implement the proposed plan. Further,
<br />the Division should revise the proposed plan to include water quality
<br />analysis, at least on an annual basis, of the deep rock and alluvial
<br />wells. We believe this is necessary because of the projected rise in
<br />total dissolved solids and for stipulation No. 6 to be effective.
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