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~~ • DATE: February 3, 1985 T0: Mike Savage FROM: Anne Baldrige ~G~ • III IIIIIIIIIIIIIIII 999 RE: Peerless Resources Inc., Coal Gulch Mine Preliminary Adequacy Comments. Following are my comments on the above referenced permit application. I have arranged them according to the appropriate rules. 2.04.6 - Geology Description 1. The potential or existing aquifers in the general area have not been identified. 2. Map 7, Coal Gulch Mine Geology/Hydrology shows the axis of the Perine Peak Syncline as running through the southeastern corner of the permit boundary. This appears to be a major structural feature of the area and the permit application should include a discussion of this under subsection Structure. 3. The permit application does not contain a discussion of the general area or regional geologic structure. 4. On page 2.04-14 the applicant discusses the lack of subsurface water. In view of the acidic content of the water present in the final strip pit of the Arness - McGriffin Mine, the Division feels that subsurface water is present. During field inspections, the presence of water has been noted in the unsealed portals adjacent this pit. This discussion needs to present more substantive information regarding the presence or absence of subsurface water. Some of the questions that need to be addressed include: Was any water encountered during drilling? Several wells are located on Map 7. In what unit are these wells completed? Is this unit continuous onto the permit area? What are the well yields for these wells? Could mining affect these wells? 5. The drill logs in Exhibit 7 indicate coal present other than the coal in the "C" and "A" seams. Rider seams and other major seams ("B" seam) should be addressed. No water levels were shown with these logs. Are they available? 6. Page 2.04-15 states that there are no potential problems with the overburden and interburden analyses. Based on the data presented, this statement is not correct and the data should be re-evaluated with regard to potential acid-forming and toxic-forming substances. 7. Page 2,04-15 states that overburden and interburden samples were obtained but does not go into detail on how these samples were obtained or where they were obtained from. This should be addressed in the permit application. 8. Page 2,04-15 classifies the overburden and interburden samples collected, however these classifications do not agree with the analyses in Table 2.