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E. chemical analysis of the coal seam for pyrite, marcasite and sulfur <br />content. <br />As a basis for the waiver, the Blue Flame Coal Mine and National King <br />Coal Mine permit applications were referenced as containing the <br />appropriate information. A review of these documents has found that a <br />portion of the King Coal application may be used to partially justify the <br />requested exemption. <br />The King Coal application and the La Plata Coal application contain <br />percent pyrite and total sulfur analyses for the coal seam. La Plata <br />Coal does not need to reanalyze for these two parameters. <br />Neither application contains coal analyses for marcasite or sulfate <br />sulfur. A coal sample from the seam to be mined at the La Plata No. 1 <br />Mine should be analyzed for these two parameters. Coal from a freshly <br />exposed face from within the mine will provide a good sample. <br />2. The application should be revised to include roof and floor textural <br />analyses. A sample of both the roof and floor of the existing La Plata <br />No. 1 Mine should be obtained and each analyzed for percent sand, percent <br />silt, and percent clay. <br />3. Rule 2.04.6(2)(a)(iv) states that when a highwall has been cut to expose <br />the coal seam overburden, samples from the exposed overlying strata <br />should be obtained. These samples should be sufficient to describe the <br />lithology (physical characteristics) of the overburden. A chemical <br />analysis of the strata immediately above the coal to be mined should also <br />be done. These analyses will help to identify the presence of potential <br />acid-forming, toxic-forming or alkalinity-producing materials. It is <br />suggested that a chemical analysis for each of the following parameters <br />be done for the over-lying strata: pN, electrical conductivity, sodium <br />absorption ratio (SAR), calcium (Ca), magnesium (Mg), nitrate-nitrite, <br />sodium (Na) and iron (Fe). One analysis consisting of a composite sample <br />of the overlying strata (exposed at the highwall) should be sufficient. <br />' Portions of the King Coal Roof and Floor analysis (arsenic (As), boron <br />(B), manganese (Mn), selenium (Se), zinc (Zn)) may be referenced in the <br />La Plata Coal application. <br />4. Two pages of the Geology Description, pages 2.04-10 and 2.04-11, are <br />missing from the permit application and need to be submitted. <br />5. The geologic information presented on page 2.04-13 does not appear to <br />correspond to the drill log (Figure 2) submitted with the application. A <br />stratigraphic column which describes the mine site should be developed <br />based upon the exposed strata at the mine site highwall cut. <br />6. The statement regarding the presence of acid-forming and toxic-forming <br />materials (page 4.05-6) should be reevaluated when the results of the <br />geochemical sampling requested above, are received by the applicant. <br />-3- <br />