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.., .. . . <br />© Resaonse Leer <br />1?/9/98 <br />Plge ? <br />Response -The only activities identified or discussed in the NOI chat would not <br />normally be considered exploration acttvittes are trenching and installation of <br />discharge lines. While the NOI does indicate chat up to four drillholes will be <br />completed as mine dewatering wells, there is no statement or intent that any mine <br />dewatering activities will occur under the NOI. As a clarification, installation of <br />monitoring wells, well development, ground water sampling, and well testing to <br />determine aquifer characteristics are all considered exploration activities under the <br />definition of "Coal exploration" contained in Rule 1.04(22). <br /> <br /> <br />Specifically, "Coal exploration" as defined under Rule 1.04(22) includes, "... field <br />gathering of surface or subsurface eog lozic, physical, or chemical data... " and <br />`... disturbance of natural land surface in the gathering of environmental data to <br />establish the condition of an area before. beginning surface coal mining and <br />reclamation operations... ". Funher, the requirements for eog loeic and hydrologic <br />information under Rules 2.C4.6(1)(c) and (d) and 2.04.7(1)(a) and (b) specifically <br />include information on ground water occurrence, aquifer characteristics, and other <br />information required to assess the potential for material damage and assist in the <br />preparation of the Probable Hydrologic Consequences statement. The DMG, in <br />their comments on the recent Technical Revision submittal (TR-32) for initial <br />development of the proposed Elk Creek Mine, specifically requested information on <br />hydrologic characteristics. The drilling, sampling, and aquifer testing activities <br />proposed under the NO[ are designed and intended to address this request consistent <br />with the applicable regulatory provisions for "Coal exploration" and "gathering of <br />environmental data". <br />Well casing, completion, development, sampling, and testing are part of the <br />exploration process and cannot be readily separated out since they involve the same <br />locations, activities, equipment, and personnel as drilling operations. OMI proposes <br />to complete initial sampling of ground water monitoring wells upon well <br />completion and development, and pump testing of the dewatering wells co establish <br />aquifer parameters for planning and permitting. OMI will continue ground water <br />monitoring using a combination of wells in order to chazacterize ground water <br />conditions for permitting purposes. OMI does not propose any subsequent <br />dewatering activities in conjunction with the NOI Application. Any future <br />dewatering activities will be addressed in conjunction with permitted mining <br />operations under the pending Technical Revision Application (TR32). <br />OMI proposes that the dewatering wells be plumbed in and discharge lines be <br />installed in conjunction with the exploration activities in order to avoid repetitive <br />disturbance and optimize handling of discharge from the proposed ground water <br />monitoring and dewatering wells during well development and pump testing. A <br />single trench would be excavated adjacent to the existing road for the water supply <br />and discharge lines (at the trench invert) and the electrical power cable Eor the <br />dewatering well pumps (above the pipelines). By installing and plumbing in the <br />discharge line, dischazge water from both well development and pump testing could <br />be controlled and dischazged to Elk Creek at the selected location with minimal <br />potential for erosion and sedimentation. The alternative would be the use of flexible <br />