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~ . r III IIIIIIIII I asR <br />~- <br />STATE OF CU~~>~LJO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman 51., Room 215 <br />Denver, CO 80203 <br />Phone: 13037 888~35h7 <br />FA%:1303183?-8106 <br />September 21, 1992 <br />Mr. ,lack Purdy <br />Pennsylvania West Coal Company, Inc. <br />626 West Pender Street, Suite 907 <br />Vancouver, British Columbia, Canada V661 V9 <br />RE: Completeness Evaluation, Coal Gulch Permit Application, C-92-079 <br />Dear Mr. Purdy: <br />OF' ~n~0 <br />Q: 4 <br />~? b <br />~o <br />~: + <br />rB]6 <br />Roy Romer <br />Governor <br />M¢hae~ B. Long <br />Division Director <br />The staff has reviewed the comments from Gene Larson responding to the Division's <br />request for baseline data. The information provided is inadequate to allow the Division to <br />deem the permit application complete. Responses to Mr. Carson's comments follow; <br />however, the Division's request for information in accordance with the August 3, 1992 <br />memo still stands. <br />A. Drill hole baseline information is imperative for evaluating the baseline geochemistry <br />at the site. Information derived from field samples acquired from the highwall of <br />the portal area can certainly be used to supplement information derived from the <br />drill holes, as proposed by Mr. Larson, but they certainly do not tell the entire story. <br />For example, the samples acquired from the portal area may not adequately <br />represent the geochemistry of the mine, in that the portals are located 3200' from <br />the center of the first year's workings in the mine. Additionally, the permit <br />indicates that the geological history is that of aregressive-transgressive shoreline <br />sequence; as such, substantial changes in lithology can occur within fifty feet in <br />such facies deposits, and more so in distances of over half a mile. The Division <br />could consider allowing Pennsylvania West to drill only two holes spaced to <br />maximize the information derived, since the permit area is only 289 acres and the <br />highwall samples have been collected. Depending on the geochemical nature of the <br />results and their replicability, however, a more intense sampling scheme could be <br />required at a later date. <br />Mr. Carson's letter does not respond to the request for information on the physical <br />characteristics of the aquifer. As stated earlier, the need for this information is <br />required by Rule 2.04.6131(al(iii)(A) and 2.04.7(1)(b). <br />