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-2- ~L ~{ ~` rl ~~~~\ "V January 10, 1989 * 5. On Page 111 through 115, the projected impacts of the operation to ground water and surface water quality and quantity are discussed. This section should be updated to include a discussion of observed @~~ , impacts to date, and the original projections should be modified if ,~`~ warranted (based on data collected since the permit was issued). P~h Annual hydrologic reports should provide a basis for any modification of the hydrologic impact projections. Changes which have been observed with respect to quality or quantity of monitored bedrock aquifers, springs, or surface waters should be thoroughly evaluated and discussed. 6. The plan for collecting, recording and reporting of ground and surface water quality and quantity data decribed on Page 114 of the Renewal Application has been substantially revised as a result of na`?` Minor Revision Ho. 3 and the Midterm Review. The application text ~~ should be updated to outline requirements of the current plan, ~ including sample site I.D., sampling and reporting schedule, o'\~ laboratory and field parameters, and Annual Hydrologic Report (AHR) ~~ requi rements. Ci v~ r ~ 7. The second paragraph under Section (3)(a) on Page 111 of the Renewal Application contains statements to the effect that baseline data was insufficient to allow for assessment of hydrologic impacts. Obviously, this situation was corrected and sufficient information was submitted or the permit could never have been issued. The paragraph should be revised to eliminate the misleading statements. ~~` 8. In the final paragraph on Page 111 it is stated that there are no aquifers that will be impacted or interrupted by the proposed activity. It is then stated that water is found in lenticular sandstones, fractures and coal seams. The two statements seem contradictory and the meaning needs to be clarified. * 9. On page 24 it is stated that pit infl ows are expected to be 100 or 200 gpm in early pit development. This discussion should be expanded to include a description of the pit inflows actually encountered, including flow rate, duration, apparent source of inflow, and how the inflows were handled during operations. Any apparent impact on downgradient bedrock water levels and spring and seep flow rates due to pit inflows should be discussed. 10. Subsequent paragraphs on Page 24 and 25 consist largely of excerpts from adequacy review and response letters. The paragraphs are not well integrated into the text and the section should be revised and updated for clarification.