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2. The Division, in reviewing and approving the National King Coal Mine <br />permit, determined that Hay Gulch is an alluvial valley floor (AYF). <br />This finding was reiterated upon the issuance of the Proposed Findings of <br />Compliance for the adjacent Blue Flame Coal tAine. Based upon these <br />findings, the applicant should revise the application to delete reference <br />to the "possible Hay Gulch AVF" and substitute "Hay Gulch AVF" throughout <br />the permit application. <br />3. As the applicant indicates on page 2.06-5, the Division is concerned <br />about potential effects to the quality of the water within the Hay Gulch <br />alluvial aquifer when water which is detained in the sediment pond <br />infiltrates into the AVF. To alleviate these concerns, the applicant <br />should develop and present a plan for sealing the sediment pond to <br />minimize infiltration into the Hay Gulch alluvial aquifer and develop a <br />plan to monitor the Hay Gulch alluvial aquifer immediately down-gradient <br />from the sediment pond. This plan should include the following: <br />A) The proposed well location; <br />B) a diagram depicting the proposed well completion methods and <br />materials; <br />C) a proposed method of determining aquifer transmissivity in the <br />vicinity of the well; and <br />D) a description of a quarterly monitoring program which should include <br />a proposal to measure depth-to-water and the specific water quality <br />parameters proposed to be monitored. <br />4. The applicant may delete the following specific commitments on page <br />2.06-5: Determine the depth and width of the Hay Gulch alluvium; <br />determine the storativity of the alluvial aquifer; determine the "Depth <br />of Molthing" [sic]. A transmissivity value should be obtained by <br />conducting a single hole aquifer test, as committed to by the applicant. <br />Application Section 4.0 - (Rules 4.05.13. Surface and Ground Water Monitoring: <br />1. Based on modifications made to preceding portions of the permit <br />application, La Plata Coal will need to modify this section. The <br />Division suggests that in those areas of the application that would be <br />duplicated in this section, a reference to that particular area be made <br />here rather than recopying portions of the application. <br />2. Page 4.05-8 contradicts the discussion on page 2.06-5 pertaining to <br />ground water monitoring. Please correct this. <br />3. La Plata Coal needs to address the presence of acid and toxic forming <br />material based on roof and floor analyses from the La Plata No. 1 Mine. <br />If acid or toxic material is present, the applicant needs to submit plans <br />for mitigation of those impacts. <br />4. The discussion pertaining to post-mining land use (pages 4.16-1 to - <br />.17-1 needs to be expanded upon to address the cropland reclamation. <br />-10- <br />