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~- Page Two Preliminary Adequacy Review Grand Mesa Coal Co. - Red Canyon Mine April 28, 1981 4. An analysis of the "D" coal seam, as required by 2.04.6(2)(a)(iii)(C) must be submitted. Both the "E" seam and the "D" seam analyses should include ~ organic, a pyritic, and sulfate sulfur. 5. Rule 2. 04.6(2)(a)(iv)(C)&(D) require physical and chemical analyses of roof, floor and interburden material. Attached as appendix A is a list of the parameters requested by the Division to make written findings re- lated to hydrologic consequences and potential for reclamation. In some cases, given local environmental conditions, not all of these parameters will be required. Should the applicant feel that adequate information has been obtained From on-site data collection or another substantiated source to indicate that a parameter or parameters do not warrant testing, then a thorough analytical discussion related directly to the specific characteristics of the mine should be included in the application. 2.04.7 Hydrology Description 2.09.7 (1) Groundwater I. Additional water quality parameters may be required in subsequent monitoring of both groundwater and surface water. Attached as Appendix B is the list of parameters requested by the Division. Exemptions from including certain parameters may be allowed if the applicant can substantiate that the particular parameter does not warrant testing (see comments under 2.04.6, item 5 of this letter). Grand Mesa has not included aluminum, nickel and sulfide in the analyses. Baseline data submitted in the mine plan contain analyses for only one sample. Quarterly samples should be taken for a full year to determine seasonal variations. 2. At least one monitoring well should be completed in the alluvial aquifer, above the subcrop, to monitor the induced recharge (approximately 100-1000 gal/min) referenced on page 61 of the mine plan. Water quality data should also be sampled at this well. The applicant should detail how the proposed monitoring plan will document the assessment of probable hydrologic con- sequences with respect to the projected area of influence of mining upon the alluvial groundwater. 3. The applicant states of page 60 of the mine plan that the Lasater and Cargill wells need to be monitored on a regular basis to insure adequate water supply. A schedule for monitoring and a list of parameters should be submitted. 4. The six piezometer wells to be sampled quarterly for water elevation should be sampled for quality at the same time, or justification provided for omitting the quality analysis. 2.04.7 (2) Surface Water 1. The location of all surface water bodies has not been provided. Page 62 of the mine plan refers to Land Use Map 2.04.3(2)(1)-1 for the locations, but this map is inadequate.