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3. Please indicate in your discussion of "Coal Reserves - <br />General" what area of percentage of each lease is within <br />the permit area, including the 35.5 acres identified <br />boundary change which is a part of this revision. <br />4. The last paragraph of page 3-32 should be updated to <br />reflect recent usage and include latest projections unless <br />these have not changes. <br />III. Hydrologic Balance <br />Ground Water - Rules 2.04.5, 2.04.7, 2.05.3, and 4.05 <br />The presentation of groundwater baseline water quality in a <br />permit application is regulated by 2.04.5(1) and 2.04.7(1), <br />which require a description of physical and chemical <br />characteristics of all aquifers within the overburden down to <br />and including the aquifer below the coal seam. In addition, the <br />Division has prepared guideline for baseline data collection <br />which recommend months of monthly water level acquisition as <br />well as semi-annual water quality evaluations. The West Elk <br />Coal Company has provided water quality data for three months <br />from three wells in the B-seam, which has been supplemented by <br />monthly water level data for two years which was collected ten <br />years ago. However, as noted below the historical data at this <br />site may have no bearing on current data. There is no data on <br />the underlying 'regional' aquifer, the Rollins Sandstone, twenty <br />feet below the B-seam, nor any significant data on an <br />interburden aquifer. It appears that the Lower Marine Sandstone <br />is a continuous formation throughout the permit area which <br />should be tapped to evaluate its characteristics as the <br />overlying aquifer to the B-seam and the underlying aquifer to <br />the E-seam. <br />Supplemental Data from the Public Domain on the Rollins Sandstone <br />1. Please submit and prepare a plan to monitor the aquifer <br />within the permit area. <br />2. Please include at least three wells from the B-seam, an <br />aquifer overlying the seam itself, and the Rollins <br />Sandstone in the hydrologic monitoring plan per Rule <br />4.05.13(1 ). Please commit to monthly water level <br />collection as well as semi-annual full suite analyses of <br />these sites. <br />3. The baseline data for the B-seam shows a considerable <br />amount of geochemical discrepancy between sites as noted <br />in the table below. <br />