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i ` • • <br />parameters is included with this letter. This information is needed to <br />identify strata that may be acid forming, alkalinity forming, toxic <br />forming, salinity forming, combusible or unstable. The data from the <br />analyses will be used to assess vegetation success, impacts of mining <br />on water quality, and to support statements concerning hydrologic <br />consequences and impacts of mining. The applicant should include the <br />name of the laborartory and the method of analysis. <br />6. The applicant must provide a structural contour map for the Cass <br />Seam. <br />7. TBM must provide isopach maps of both coal seams to be mined. <br />Hydrology 2.04.7 <br />1. The applicant should submit the raw data used in the pump tests. <br />Information should also include dates, locations, and methods of all pump <br />tests and observation well results. <br />2. The applicant could not provide information on the source of water <br />for the wells listed on Table IV-7. The applicant should obtain and <br />submit the State Engineers well records for these wells that would enable <br />the Division to determine which aquifers the wells were completed in. <br />3. The Division requires a years baseline data on surface water quality <br />and quantity in sufficient detail to assess seasonal variations in flow <br />and quality. The applicant may also comply with section 2.04.7 (surface <br />water) by providing accurate descriptive and predictive information on <br />surface water quality and quantity based on extrapolation by an expert <br />in the field from documented data on water quality and quantity of <br />similar areas, provided that the data used by the expert is included in <br />the application and is approved by the Division. <br />TBM has attempted to characterize flow in the Del Agua drainage 6y <br />extrapolating data on stream flow from the Apishapa River. The method <br />used to extrapolate the data is not acceptable to the Division and was <br />never approved by the Division. The following problems were identified <br />with the methods that were not addressed or taken into consideration <br />by TBM. <br />I. Data Base Problems <br />A. Time of Record (Stream flow records of 1940-1950 do not take <br />into consideration the increase in development during the past <br />30 years. Urbanization, agricultural development, etc., can change <br />runoff characteristics greatly.) <br />B. Water Consumption (Increased water use over the past 30 years <br />can have a significant impact on stream flow.) <br />C. Frequency Analysis (Having I1 years of data and using the highest <br />point does not necessarily define a 10 year event. This is a <br />statistical event which in reality may not occur during a given <br />(21 <br />