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ADEpUACY ISSUES I. Legal. Financial :and Compliance Information - Rule 2.03 1. The application form must be updated to reflect the revised "affected" and "disturbed" acreage within the permit area and other changes that have occurred since the original application form was prepared. "Disturbed area", as defined by Rule 1.04(6) would Include regraded 2J 494u.e areas at Pits 1, 2, 3, 5 and 6, as well as existing and proposed disturbances at pit 4. Road acreage is also included as "disturbed area°. II. Geologv - Rules 2.04.5 and 2.04.6(1) 1. Coal extraction during the permit term is to be limited to Pit 4. The following geologic Information must be provided with respect to mining at Pit 4. a) A geologic cross-section through the mine area at Pit 4 should 3 C~u i be provided which delineates (as required by Rule 2.04.6(1)(a)(1)) fru'~' "the nature, depth and thickness of the coal seams to be mined, i,(,,,~•~'~ any coal or rider seams above the seam to be mined, each stratum t of the overburden, and the stratum immediately below the lowest ' ~.~; ~~ „ r=,c Yr_, coal seam to be mined. It is not clear from the text or the cross-sections provided (which do not bisect Pit 4) which coal seams are to be extracted. This information 1s required. Overburden and interburden strata which can be correlated from ltthologic log Information should also be depicted in the cross-sections. Mined sections should be delineated. b) Rule 2.04.6(1)(b)(i)(D) requires chemical analysts of each overburden and interburden stratum and the stratum immediately below the lowest coal seam to be mined. The applicant has provided highwall samples to a depth of approximately 35-40 feet from the boxcut at Pit 4. However, on ~~~;~ page III-30 of the application, it 1s stated that the maximum S highwall will occur at the first boxcut and will be approximately ~G"~' ~ ? 70 feet. The applicant should clarify whether the strata from tiu 3~2;~ ' which the "underburden" samples were collected is the lowest 7 strata to be encountered, or whether a deeper seam is to be No s ~`"~~ extracted. I')D~ G(ecv, fl////~'cu.tf ,~ic.c~.es yes, ~,,,,t c~~Cs a- ~ercrclol~~` ~~rc~ np 2. Electric and 1lthologic logs bracketing mined sections from each pit should be provided. Coals mined versus coals discarded should be noted and the Blacksmith and Pinnacle seams should be designated on logs. (~L Accurate analyses of the impact of mining on water quality cannot be made unless overburden sample data can be correlated with mined sections and related to monitoring data from the proposed monitoring wells.