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Peabody should incorporate into the permit additional <br /> information relevant to the Fish Creek AVF which may be derived <br /> from the new surface water monitoring sites on Bond, Cow Camp and <br /> Fish Creeks as discussed earlier. <br /> The division may want to review the hay crop salinity <br /> tolerance discrepancies between Peabody's referenced publication <br /> and the Maas publication suggested under rule 2.06.8(5) (c) (i) as <br /> outlined earlier in this document. Peabody claims irrigation water <br /> with up to a 3 mmhos/cm Specific Conductance may be used <br /> occasionally on the Fish Creek AVF without any detrimental impacts. <br /> This may be problematic when considering the Orchardgrass grown on <br /> the Fish Creek AVF has a considerably lower Maas salt tolerance of <br /> 1 mmhos/cm. Even at 1 mmhos/cm, however, the TDS levels in Fish <br /> Creek have historically been acceptable and non-injurious to crops. <br /> In light of the previous comments and with the acceptance of <br /> the salinity tolerance levels offered by Peabody, the division <br /> should therefore make the following finding with respect to the <br /> Fish Creek AVF, the only OMLR designated, non-exempted AVF adjacent <br /> to Peabody Coal's Seneca II mine. <br /> Peabody's proposed Seneca II surface coal mining and <br /> reclamation operations will: <br /> 1) Avoid during mining and reclamation the interruption, <br /> discontinuance, preclusion of farming on flood irrigated or <br /> subirrigated alluvial valley floors: 2.06.8 (4) (a) (iii) ; <br /> 2) Not cause or present an unacceptable risk of causing material <br /> damage to the quantity or quality of surface or ground waters that <br /> supply the alluvial valley floor: 2.06.8(4) (a) (iv) and; <br /> 3) Be conducted to insure that the important characteristics <br /> supporting the essential hydrologic functions of alluvial valley <br /> floors in areas not within the permit area are preserved during and <br /> after mining: 4.24.4(1) (b) . <br /> cc. Larry Routten, Senior Specialist <br />