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Permit Revision Adequacy July 6, 2004 Page 5 of 18 32. Table 4 on page 2.04-57 should be amended to include the data from the wells in the E-seam and the alluvium of the Dry Fork of Minnesota Creek. 33. Please include a discussion of the baseline groundwater data MCC is providing for the SOD permit revision, including a summary of data from the E-seam and aquifers above and below, as specified in Rule 2.04.7(1). 34. On page 2.04-57, the penultimate pazagraph discusses water levels in monitoring well SOM-C- 76, completed in the F-seam, responding to drought years. Please correlate the observation with the discussion on "active" and "inactive" zones and if MCC is implying that this well is in an "active zone?" The conclusion that water in the seam is "active" water has strong implications in the analysis of the groundwater system in the SOD area. 35. On page 2.04-58, can any meaningful observations be added on water in the E-seam from E- seam development to date? 36. On page 2.04-58, in the first paragraph of "Barren Member" section, the description of "highly lenticular" sandstone is used. Please explain what is meant by that. 37. On page 2.04-69, the same observation applies as in #18. Please include data from the springs and a discussion in the text rather than just refemng to the data as contained in the AHR. 38. MCC has collected baseline surface water data on most of the streams which will be affected by SOD mining. In the surface water baseline monitoring program, beginning on page 2.04- 71, MCC further commits to collect baseline data or to reinstate data collection in the summer or the year before mining impacts aze anticipated in the SOD azea. These commitments are found on pages 2.04-76 (for some surface stations) and on page 2.04-78 (for portions of the spring monitoring program.) In PR-10, MCC is proposing to mine in the Minnesota Creek drainage basin. Please provide a detailed monitoring plan and schedule for the surface water quality and quantity and spring information in the SOD azea. In particulaz, the Division feels that data should be provided for the Deep Creek ditch trans-basin diversion, Deer Creek, Poison Gulch, South Prong and the upper East Fork of Minnesota Creek, as portions of the drainage basins of these streams will be undermined by SOD activity. 39. On page 2.04-73, the last sentence contains a minor typographical error. 40. Similaz to question #18, while complete analyses of groundwater quality are contained within the annual hydrology reports, as noted on page 2.04-77, the Division requests that MCC include a presentation and discussion of the data within the PAP in response to Rule 2.04.7(2)(b)(ii). 41. On page 2.04-79, MCC comments on the springs in the SOD azea. It would be instructive to determine if these springs are active now after several drought yeazs when MCC evaluates whether these springs tap a colluvial source or a bedrock source (i.e. "active" vs "inactive".)