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Mr. Springer - 2 - January 30, 1987 2. Bear Coal Company needs to obtain a rider to its insurance policy. The rider shall require the insurer to notify the Division when any substantive changes are made in the insurance policy per Rule 2.03.9(3). The current Bear insurance policy does not contain this provision. The original rider shall be submitted to the Division. Copies of the insurance certificate and rider shall be inserted in Exhibit 3 of the permit application. 3. Bear Coal Company needs to di ;cuss the amount of topsoil that it intends to place on the Disturbed area. Bear also nerds to discuss why no subsoil has be?n s*.ockpiled at the mine site. This information shouli be inserted into section 2.05.•'. of the permit application. This information c•?uld not be found in the application and affects the reclamation plan. 4. Bear Coal Company is requested to submit a reclamation plan timetable for the Bear Mine per Rule 2.05.4(2)(a). The timetable should be contingent upon the termination o` mining operations. The timetable should reflect the times at which each phase of reclamation is expected to commence. The timetable should be inserted into section 2.05.4 of the permit application. 5. Sear Coal Company needs to address the possible contamination of the alluvium underlying the Fue~ transfer and storage area and propose a mitigation strategy. The proximity of the alluvial water *_able to the land surface, app••oximately 2.0 feet, creates the possibility of contamination of *he ground water. The operator has gravelled and bermed this aria to prevent contamination of s•~r;ace water. This gra~:el does not prevent the downward migration of o'1 and grease into the alluvial waters. u. `~?nr• ~:~idl Company 15 re a~c<tan hn inner: a CeSC rlrtlC~. .r;f the .. ,.. r2'.. hydrologic monitoring plan into the permit application. The approved hydrologic monitoring plan is located in the February 16, 1981 permit application and is referenced from section 2.04,7 of the current permit appl'cation. This system of re'eren~ing is cumbersome and c.:nfusing. :n addition, the monitoring plan that is referenced is not current. Narrative discussion of the current monitoring plan should be inserted in ~zction 2.04.7. The description of the monitoring plan shall include monitoring frenuency, water quality parameters monitored, and water level or flow measurements. Appropriate information should be submitted for surface and ground water monitoring site. The description should also include a submittal date for the Bear annual hydrologic report and well completion information for all monitoring wells. Bear Coal Company shall also submit a sprir~g and seep survey for the Bear No. 1, No. 2, and No. 3 !dines. Ti~is survey will help identify any mine drainage from the portals for Bear No, 1 and dJo. 2 and will also indicate saturated areas of the surficial material. Areas of saturated surficial materials may be potential a:-eas of slope instability. The spring and seep survey should be conducted during April or M1lay. Bear Coal Company is also requested to add a visual check for oil and grease to its ground water monitoring program. Oil and grease needs to be monitored to determine if alluvial ground water is being contaminated by effluent migrating downward through the alluvium.