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<br /> <br />Permit Application P,enewal Comments <br />The second paragraph on Page 4 of the Renewal Application Form states that the <br />pennit renewal "narrative should describe the conditions which have been <br />encountered during the previous pennit term, and analyze how those conditions <br />compare with those anticipated in the original permit application". <br />The above requirement has not been met fora number of information categories, <br />and this is the reason for many of the comments and requests set forth below. <br />Legal, Financial, and Compliance Information <br />Pueblo Coal should revise the information on Page 13 of the Renewal <br />Application to list permit numbers for those permits lacking the <br />numbers. Also, the final air emissions permit for Appendix 3-4 <br />should be submitted. (See Midterm Review document - Page 8, Item 3) <br />II. Land Use <br />The first paragraph on Page 19 of the Renewal Application references a <br />"planned" vegetation study to be conducted in 1980. The study was <br />conducted in 1983 and the paragraph should be revised to reflect that <br />fact. <br />V, VI, and VII. Ground Water and Surface Water Hydrology, and Probable <br />y ro ogic onsequences <br />~ A`-)" ~~2. The operator should submit to the Division the data collected <br />during the 1985 drilling program. (Midterm document - Page 8, <br />Item 4e) <br />* 3. Item 4g of the midterm document specified that ground water and <br />surface water data collected on a quarterly basis should be <br />submitted yearly as an Annual Hydrologic Report (AHR). The AHR was <br />to be based on a water year (10/1 throuoh 9/30) to be submitted no <br />later than December 1 of each year following the reporting period. <br />The report was to include all reduced and tabulated hydrologic data <br />collected during the year, as well as an interpretation of the data <br />and a discussion of any trends or impacts to the hydrologic system. <br />IJe do not have on file AHRs for water years ending September 30, <br />~c~ 1986, 1987, or 1988, although we do have quarterly data for 1986 <br />and 1st and 3rd quarter data for 1987. The missing AHRs will need <br />to be submitted as soon as possible. <br />* 4. In the second paragraph on Page 36 of the Renewal Application, it <br />is stated that surface water sampling verified the insignificant <br />~ surface water contribution of the Carbon Junction Canyon drainage <br />~,u'-, ~ ^ area. The type of sampling conducted and the result obtained <br />P ,~ should be discussed to provide support for the statement. <br />