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Permit Revision Adequacy July 6, 2004 Page 4 of 18 2.04.7(])(a)(v). This is necessary to provide the information needed in evaluating points of compliance for groundwater monitoring. 23. On page 2.04-53 MCC states that "no aquifers have been identified in the Upper Coal Member, the Lower Coal Member or Barren Member of the Mesa Verde formation in the West Elk coal block." Discussion presented on the succeeding pages contains a great deal of relevant information and observation, but no cleaz, concise support is provided for the assertion that no units can be considered an aquifer by the definition in the CDMG Rules ("...a zone, stratum or group of strata acting as a hydraulic unit that can store or transmit water in sufficient quantities for beneficial use.") Please discuss in detail the data and analysis that lead to the conclusion. 24. On page 2.04-54 , in the discussion of the Rollins sandstone, see the previous comment. Please state and support the contention that the Rollins sandstone does not constitute an "aquifer" in the West Elk mine permit area. 25. On page 2.04-54, in the last paragraph, please add to the description a statement describing how long it would take a given unit of water to travel a given distance. (This will provide a reference for readers of the text.) 26. On page 2.04-55, in the first paragraph, the statement is made that there are important similarities between the Bowie and the Rollins sandstone. Please describe these important similarities alluded to in the discussion and reference the relevant data. 27. On page 2.04-55, please discuss the presence or absence of groundwater seeps at Bowie sandstone outcrops. 28. The discussion beginning on page 2.04-55 refers extensively to the Cumulative Hydrologic Impacts Analysis (CHIA). Those references are not appropriate in the context of the permit application. The data and observations on geology, hydrogeology, stratigraphy and structure are all secondary, derived from primary sources including the permit applications from the North Fork mines and others. This discussion should reference primary sources. References to conclusions drawn or calculations made in the CHIA by the Division is appropriate, but not the listing of data. 29. On page 2.04-56, in the first paragraph, MCC seems to be saying that the transmissivity values derived from aquifer tests in the B-seam were so low that meaningful conclusions could not be drawn. Is that the case? Please reference the data used and add a concluding statement to the text. 30. On page 2.04-56, in the section "Upper Coal Member" the discussion on sandstone channels, aze there any relevant observations where these formations crop out? If so, please discuss. 31. On page 2.04-56, in the last line, is "Bowie shale" intentional or should it be "Bowie sandstone?"