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The report by Cameron Engineers ( "Preliminary Geologic Field Mapping, <br />Scullion Gulch Area, Rio Blanco County, Colorado ") referenced on page <br />II.B -5 of the permit application should be provided as part of the permit <br />application. <br />The east -west cross - section provided in Figure II.B -2 of the permit appli- <br />cation does not include a large part of the easternmost portion of the <br />permit application. An additional cross - section (or offset to the exist- <br />ing cross- section) should be developed for this area, and submitted as a <br />part of the permit application. <br />The results of chemical analyses presented for the overburden (roof, <br />floor, interburden and coal) in the Western Fuel permit application are <br />not consistent with results from other overburden analyses performed on <br />the Williams Fork Formation. The concentrations of the following para- <br />meters are suspect: Total Sulfur, Sulfate Sulfur, Pyritic Sulfur (Fe2S), <br />Organic Sulfur, Molybdenum, Cadmium, Copper, Lead, Nickle, Arsenic, Zinc, <br />Mercury, Chromium and Selenium. The low reported concentrations are the <br />result of the methods of extraction used by the laboritory. The excepted <br />methods of extraction are noted on Appendix B of this review (Baseline <br />Overburden Chemical - Mineral Analysis, and Reference to Extraction Meth- <br />ods). These methods of extraction for heavy metals are designed to repre- <br />sent worst case condtions of plant availability (that which plants can up- <br />take). Those parameters which should be re- analyzed are only those high- <br />lighted in yellow in the Baseline Overburden Chemical - Mineral Analysis <br />sheet attached as Appendix B. <br />Section 2.04.7 Hydrology Description <br />(1) Ground Water Information <br />(a) <br />The applicant needs to further discuss the "relatively high yield" massive <br />-3- <br />