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-3- PART II - ADEI]UACY ISSUES Y The following adequacy issues were identified. These adequacy issues are being sent to the applicant in order to expedite the permitting process. The applicant has been accepted into the Small Operator's Assistance Proyrain (SOAP). This program is designed to help the small operator in obtaining and interpreting data related to the probable hydrologic consequences of mining, A number of the adequacy issues identified will be addressed by the SOAP program. These issues are identified by an asterisk (*). Rule 2.03.4 - Identification of Interests 1. Rule 2.03.4(1) requires that the Haines and addresses be provided for the legal or equitable owners of record and the Holders of record of any lease hold interest. The application did not contain the current addresses for the Guiliano s, the coal owners, or for Twin Pines Coal Company, the leasor. The application must contain this information. 2. The legal rights claimed by the applicant are presented on payes 3 and 4 of the application. However this information is insufficient to explain the riyhts to construct surface facilities as required by Rule 2.03.6(1). The applicant must explain the legal rights granted under the leases fur construction of surface facilities. 3. The insurance policy presented in appendix 8 does not cover the operation as required by Rule 2.03.9. TYie certificate must provide for both personal injury and property damage protection. Also, the minimum coverage must be $300,000.00 for each occurrence and $500,000.00 aggregate. Rule 2.04.3 - Land Use Information 1. The surface disturbances of the previous underground mining as shown on map TP-1 have not been presented in the application. As required in Rule 2.04.3(3)(f). The Division suggests that the surface disturbances also be shown on map TP-l. Rule 2.04.6 - Geology Description l.* The application does not contain analyses of the roof and floor materials for all of the proposed parameters as required by Rule 2.04.6(2)(a)(iv)(D). This information will be supplied by SOAP. Rule "2.04.7 - Hydrology Description 1.* The application has presented baseline hydrology information on pages 34-48 of the permit application. However, this information is insufficient to show the seasonal variation in the quality and quantity of the surface water for the permit and adjacent areas. The application will need to include quality and quantity information sufficient to show seasonal variation fur the following surface water bodies: a) Lewis Gulch, b) Oak Creek and c) South Uak (;reek. This information will be provided by SOAP.