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Dudash, Joe C ~ ~~ n <br />From: Dudash, Joe <br />Sent: Friday, August 04, 2006 1:45 PM AUG 0 4 2006 <br />To: Jim Stover (E-mail) <br />Subject: Bear No. 3 MR-27 Divisia, .,. ,.rciamation, <br />Mining and Safety <br />We have had discussions at the Division concerning the Bear Coal Company (BCC) MR-27 submittal. The <br />bottom line is that the Division does not want to see the razed mine office buried on site, particularly in the <br />spring water treatment pond. The building should be either burned completely and disposed of offsite or razed <br />and disposed of offsite. <br />The flat mine facilities area is very close to the water table and burial on site would present a problem with the <br />groundwater. Rule 4.11.4(2) deals with final disposal of noncoal waste. This rule, in part, requires that such <br />disposal must "...ensure that leachate and surface runoff do not degrade surface or ground water...". <br />The flat facilities area is basically part of the floodplain and is very close to the groundwater. When the river is <br />running high, I have seen standing water in a portion of the collection ditch next to the river berm even though <br />no recent precipitation event had occurred. Also, when the river was high, there has been an unusually large <br />volume of water in the sediment pond. I think the groundwater table rises when the river is flowing full and the <br />groundwater daylights in some depressions. <br />Although it is not stated in the proposed revised pages for MR-27, your cover letter for MR-27 implies, and <br />previous discussions have mentioned, the possibility of burying the razed mine office in the spring water <br />treatment pond once the pond is no longer needed. The problem with this is that the issue of the spring water <br />has not been resolved yet. The Division does not want to approve a revision that might imply that the spring <br />water treatment pond is not needed, and, therefore, the spring is not the jurisdiction of the mine. This has yet <br />to be determined. <br />Therefore, please inform the Division if BCC wants to pursue or withdraw MR-27. <br />Please let me know by the end of Monday, August 7 how BCC would like to proceed, since that is the last day <br />for completeness. Thanks! <br />