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<br />Michael G. Altavilla <br />Seneca Coal Company <br />Page 9 <br />November 24, 1998 <br /> <br />areas, or provide an explanation for the apparent lack of downgradient monitoring in the <br />overburden and coal aquifers in the vicinity of the South Expansion Area. <br />34. Page 112 of Tab 17 states that two farmed fields above J.R. Temple Reservoir No. 2 are <br />subimgated, with no mention of flood imgation above the reservoir. Exhibit 16-1 (Water <br />Rights) indicates flood irrigation of fields in Hubberson Gulch from the Hollatz Ditch <br />No. 1 and No. 2. This information is also discussed in Tab 16, and the fields appear to be <br />located in alluvial valley floors. <br />The Probable Hydrologic Consequences section must be updated to include the possible <br />consequences of increased surface water salinity on the irrigated fields and possible <br />alluvial valley floors located in Hubberson Gulch. <br />35. The "Regional Land Use Map" provided in Tab 4 does not show irrigated lands along <br />Dry Creek and Hubberson Gulch which are shown in Exhibit 16-1. Please revise the <br />"Regional Land Use Map" to include all local irrigated lands. <br />36. We aze reviewing the surface water salinity loading calculations for Dry and Sage Creeks, <br />relative to the Granulative Hydrologic Assessment for the Yampa Basin. Additional <br />information requests may be forwarded to SCC if questions arise during this review. <br />37. Paragraph 4, page 1, Tab 4 indicates that there aze no significant farm-related uses in the <br />azea of the mine. This seems to contradict related information in Tabs 16 and 17, which <br />indicates that such farm-related uses exist along Hubberson Gulch and Dry Creek. Please <br />revise this page as needed, or explain the possible discrepancy. <br />3.02.2 Determination of Bond Amount <br />38. The estimated costs for reclamation operations associated with the proposed South <br />Expansion Area were not included with the permit revision application package. Prior to <br />approval of this permit revision, the Division will require an updated reclamation cost <br />estimate. <br />General Comments <br />39. Exhibit 12-2A is referenced on page 5 of Tab 12. This exhibit is labeled as 12-3. Please <br />revise this page, if appropriate. <br />