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Comments <br />January 8, 1982 <br />Page Two <br />5. Anchor Coal Company, the lessee of record of Federal <br />Coal Lease D-052501 has filed an application for approval <br />of a plan for augmentation in Water Court (Water Division <br />4, Case No, W-79CW133), ARCO has filed a statement of <br />opposition. <br />6. The Bear Permit Application states that no water is <br />anticipated to be discharged from the underground mine, <br />but if encountered during the underground operation, <br />water will be treated in underground sump areas prior <br />to discharge. We find that the permit application does <br />not address the design of these sumps, a description of <br />how the water will be treated in the sumps, or an explan~ <br />ation of how and where the water will be discharged. <br />7, Section 4.05,2 - The Permit Application states that no <br />acid water mine drainage of pH less than or equal to <br />6.0 is expected, We found no reference to any evidence <br />of site specific sampling and testing, <br />8. Section 4.05.5 - The Permit Application states that <br />sediment removed from sediment ponds may be used for <br />topsoil or subsoil if it meets the proper suitability <br />criteria, However, we find no data to support the <br />contention and no procedure for handling of this sediment <br />if it does not meet the proper suitability criteria. <br />9. Page 2.04-1 indicates that the environmental data used <br />in ARCO's Mt. Gunnison Permit Application will apply <br />to the operation at the Bear Mine. Bear Coal Company <br />should generate its own site specific environmental <br />data for the seams and strata in which it plans to <br />operate. <br />10. Page 2.04-11 - General Description of Hydrology and <br />Geology. The Bear Permit Application simply references <br />data generated by ARCO and used in Gunnison Permit <br />Application. This information not only should be site <br />specific and physically present in the Application but <br />also certified as correct by an authority representing <br />Bear. The Bear Permit Application similarly references <br />the ARCO data used in the Alt, Gunnison T9 & R plan <br />groundwater section, <br />11, Page 2.05-24 - Coal Processing Wastes and Non-Coal <br />Processing Wastes. The Bear Application states that <br />"this part is mt applicable" because a dry crushing <br />method for coal preparation is to be used and therefore <br />there would be no coal processing wastes, It is our <br />