2009-08-28_APPLICATION CORRESPONDENCE - C2009087 ‎(2)‎

• Permit No: C2009087
• IBM Index Class Name: APPLICATION CORRESPONDENCE
• Doc Date: 8/28/2009
• Doc Name: Preliminary Adequacy Review of Permit
• From: DRMS
• To: Peabody Energy Corporation
• Email Name: TAK
• Media Type: D
• Archive: No

Mr. Vem Pfannenstiel
August 28, 2009
Page 3
constant head data from the calculation of means in the table. The Division is
concerned that grouping the constant head data with the slug test data is not
valid, based on the probable much greater accuracy of constant head data
compared to slug test data.
11. Please add to the text more detailed description of the aquifer test methods (for
example: isolation of test intervals in holes, hole/casing diameters in test
intervals, slug volumes, slug lengths compared to assumed saturated zone
thicknesses, water level measurement time periods, relative reliability of constant
head data compared to slug test data).
12. Please add a discussion of how the hydraulic conductivity and transmissivity
values obtained in SCCC's wells compare to the regional values reported by
Robson and Stewart (1990) for slug tests and pump tests in wells drilled to
depths similar to SCCC's wells.
13. On page 2.04-45, 2nd paragraph, should the words "aquifer test method" be
changed to "slug test method"?
14. For the calculation of vertical bedrock discharge into Grassy and Little Grassy
Creek alluvium on page 2.04-49, please explain why a hydraulic conductivity
value of 10"5 is used, rather than a value between 0.03 and 5 feet per day as
shown for interburden (PSCM's overburden) in Williams and Clark's (1994)
Table 4.
Section 2.04. 10
15. Page 2.04-123 appears to introduce a new reference area, the "Yoast Haul Road
Corridor-Improved Pasture/CRP" to Table 2.04.10-T5. This reference area is not
depicted on Map 2.04.10-M1. Is this a third reference area, in addition to the
Mountain Brush and Sagebrush reference areas? There is no discussion of the
condition of this apparently new reference area or its application to reclaimed
areas at PSCM. Please provide additional discussion, the location, and the
application of the Road Corridor-Improved Pasture/CRP reference area.
Also, Table 2.05.4-T4 includes only two reference areas, the Mountain Brush
reference area and the Sagebrush reference area. Please ensure tables show a
consistent number of reference areas.
Section 2.04.13
16. SCCC commits to submitting annual reclamation reports in accordance with
Rule 2.04.13. SCCC is incorporating previously reclaimed lands into the
Peabody Sage Creek permit that have been reclaimed for varying numbers of
years, and have been approved for various phases of bond release. Although the
historical information regarding reclamation practices for these previously
reclaimed lands is in the Seneca 11 permit, referencing this information is not