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Permit Revision Adequacy Comment Response <br />November 30, 2004 <br />Page 5 of 24 <br />• 21.On page 2.04-52, 2"d pazagraph, the statement is made that new wells have been added, <br />including Upper and Lower Dry Fork and SOM-3B and that the location and completion <br />information can be found in Table 5. Table 5 (page 2.04-58) is a summary of slug test data, not <br />location and completion data. Please correct this reference. Further, please include slug test <br />data for those new wells as available and note on the table the unit in which each well is <br />completed. <br />MCC Response: Tables were added to clarify the text. <br />22. While complete analyses of groundwater quality are contained within the annual hydrology <br />reports, as noted on page 2.04-53, the Division requests that MCC include a discussion and <br />analysis of the data within the permit application package (PAP) in response to Rule <br />2.04.7(1)(a)(v). This is necessary to provide the information needed in evaluating points of <br />compliance for groundwater monitoring. <br />MCC Response: Discussion was added and analyses summarized and updated. <br />23. On page 2.04-53 MCC states that "no aquifers have been identified in the Upper Coal Member, <br />the Lower Coal Member or Barren Member of the Mesa Verde formation in the West Elk coal <br />block." Discussion presented on the succeeding pages contains a great deal of relevant <br />information and observation, but no clear, concise support is provided for the assertion that no <br />• units can be considered an aquifer by the definition in the CDMG Rules ("...a zone, stratum or <br />~ group of strata acting as a hydraulic unit that can store or transmit water in sufficient quantities <br />for beneficial use.") Please discuss in detail the data and analysis that lead to the conclusion. <br />MCC Response: Additional text and discussion was added to clarify "aquifer". <br />24. On page 2.04-54 , in the discussion of the Rollins sandstone, see the previous comment. <br />Please state and support the contention that the Rollins sandstone does not constitute an <br />"aquifer" in the West Elk mine permit area. <br />MCC Response: MCC has added to the text, discussion that supports the contention. <br />25. On page 2.04-54, in the last pazagraph, please add to the description a statement describing <br />how long it would take a given unit of water to travel a given distance. (This will provide a <br />reference for readers of the text.) <br />MCC Response: MCC has addressed permeability and transmissivity in the text and new <br />table. <br />26. On page 2.04-55, in the first paragraph, the statement is made that there are important <br />similarities between the Bowie and the Rollins sandstone. Please describe these important <br />similazities alluded to in the discussion and reference the relevant data. <br />MCC Response: References and in the discussion have been added to the text. <br />