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<br />Overburden Sample No. 1 was classified as a shale with some amount of <br />carbonaceous shale, yet the grain size analysis in Table 2 indicated that 60% <br />of this sample is sand. A shale by definition is a laminated sediment <br />composed primarily of clay or silt sized particles. Overburden Sample No. 2 <br />was classified as a sandstone, yet the grain size analysis indicated almost <br />equal amounts of sand, silt and clay. The roof sample was classified as a <br />shale with small amounts of interbedded coal or carbonaceous shale, yet the <br />grain size analysis indicated that the grain size test could not be run due to <br />large amounts of coal. This should be corrected in the permit application. <br />2.04.7 - Hydrology Description <br />1. Both the ground and surface water sections of the permit application do <br />not adequately address the requirements of Rule 2.04.7. The applicant should <br />review this section of the regulations and revise this section of the permit <br />application. Following are specific concerns related to this section. <br />Groundwater <br />2. Potential aquifers within the proposed permit and adjacent area are not <br />identified in this section. This should be addressed including a discussion <br />of recharge, storage and discharge characteristics. <br />3. Known uses of the water in the aquifers and water table have not been <br />identified ahd discussed although several wells are located on Map 7. <br />4. The quality of subsurface water in all wells should be presented if <br />available. Water availability in these wells should also be addressed. <br />5. This section needs more detail and evidence of the lack of subsurface <br />water. There is no factual evidence presented that there is indeed a lack of <br />groundwater in the proposed permit area. See Comment 4 under subsection <br />2.04.6. <br />6. When was the mapping of springs and seeps accomplished? Have any surveys <br />for springs and seeps been done during spring runoff? <br />Surface Water <br />7. No sample of water quality in the pond was contained in Exhibit 11 as <br />stated on page 2.04-18. <br />8. The data collected for surface water quality is not adequate to define the <br />water quality of Coal Gulch. At a minimum, samples should be presented for <br />water quality upstream and downstream of the proposed mining operations over a <br />consecutive twelve month period. These samples should be co]lected on Coal <br />Gulch itself, not on adjacent streams. <br />9. No information was presented to identify seasonal variations in water <br />quality or quantity of Coal Gulch. A monitoring program for future potential <br />impacts should also be developed. <br />Alternative Water Supply <br />10. The requirements of this section of the regulations have not been <br />