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Mr. Greg Lewicki <br />Greg Lewicki and Associates <br />June 24, 1997 <br />Page 3 <br />compacted fill that came from the mine portal cut. Prior to reclaiming the <br />site in Fall 1992, Apex dug test pits in the facilities yard area to determine <br />the location and quantity of coal waste. Some of the waste was trucked to <br />nearby active mines where it was buried with backfilled spoils. In 1993, 6 <br />inches of topsoil was spread on the remaining fill in the facilities yard area <br />and the area was seeded. Since then, topsoil test borings found coal pieces <br />in the top of the remaining fill material. It is conceivable that surface runoff <br />could percolate through this layer of fill material and possibly generate <br />leachates which could adversely impact the underlying alluvium. Such <br />contamination could be detected in water samples taken from a proposed <br />down-gradient alluvial monitoring well mentioned in Item 5 below. <br />Although the potential for contamination of the Trout Creek watershed from <br />leachates seems low, the permit application should be updated to address <br />this potential and any other potential impacts to the Trout Creek watershed; <br />for example, runoff from the office area small area exemption. The <br />Division requests that a brief discussion updating these issues be included <br />in the technical revision requested in Item 4 below. <br />Proposed relocation of downstream surface water monitoring site. <br />Data from the downstream surface water monitoring station (on Trout <br />Creek 2 miles downstream from the Apex No. 2 permit area) may be <br />confounded by other mines which also lie upstream from the station. To <br />remedy this situation, Apex is considering a new downstream surface water <br />monitoring site nearer the permit area. The Division commends this <br />proposed relocation. Please submit an application for a technical revision ~R' 9 <br />which proposes the new downstream surface water monitoring station. <br />Proposed down-gradient monitoring well. Data from the existing down- <br />gradient ground water monitoring well (on the Edna Mine next to Trout <br />Creek 2.5 miles from the Apex No. 2 permit area) may be confounded by <br />other mines which are up gradient from the station. To remedy this <br />situation, Apex has proposed drilling a new ground water monitoring well <br />into alluvium immediately down gradient from the permit area. The ne~v <br />well will be completed in the 5 to 20 feet of alluvium that underlies the <br />Trout Creek valley. The Division commends this well drilling proposal, ~~-~ <br />and requests that this proposal be included in the technical revision <br />req:~ested in Item 4 above. <br />