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i~ ., <br /> <br />J.E. Stover & Associates -5- <br />Bowie No. 2 Mine <br />May 31, 1996 <br />mine workings. Faulting of this sort can become a <br />significant consideration for the operating cost of an <br />underground mine and could also be a significant source of <br />mine water inflow. A thorough aerial photographic analysis <br />of the permit and adjacent area might assist in defining the <br />location of potential faults. <br />11. A brief discussion of the acid generating potential of the <br />Upper B and Upper D coal seams are presented in the text. <br />Supporting chemical analyses are referenced within Exhibit 6 <br />of volume III. Page 2-04-18 of the application states; "It <br />is likely that lime is present in adequate quantities to <br />neutralize the acid forming component in the coal." The <br />limited geochemical analyses of the coal seams provided <br />within Exhibit 6 of Volume III show the Upper B-Seam to vary <br />from 0.4$ to 0.01$ (average 0.145$) dry weight pyritic <br />sulfur. This data also shows the Upper D-Seam to vary from <br />0.05$ to 0.01$ (average 0.027$) dry weight pyritic sulfur. <br />The data included within Exhibit 6 regarding occurrence of <br />calcium shows minimal amounts of soluble Calcium and <br />Magnesium to be present in the roof and floor rock. No <br />Calcium or Magnesium data is provided for the two coal <br />seams. No anion analyses, such as carbonate, or acid/base <br />potential determinations are provided for any of the coal, <br />floor or roof materials. The Division cannot find a basis <br />for BRL's belief that sufficient lime is present within the <br />coal to negate the formation of acid within these coal <br />seams. BRL should expand upon its conclusion regarding the <br />acid forming potential of the upper B-seam and upper D-seam <br />Williams Fork coals. <br />2.04.7 HvGrolo4v Description <br />In general, this information was presented in a very orderly and <br />professional manner. However, due to the complexity of the <br />surface water drainage system, maintenance problems may be <br />plentiful. There are twenty culverts that will be 12 inches in <br />diameter. Such culverts routinely are prone to clogging. Also, <br />several culverts have bends in them. These may be prone to <br />blockage problems as well. Finally, there are several ditches <br />which have severe bends in them. Breaching at these locations is <br />likely. <br />The Division has the following questions or comments: <br />12. On page 2.04-22 of the permit application, it is stated that <br />monitoring hole completion drawings are in Exhibit 3. <br />However, they do not appear to be in that exhibit. Please <br />