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land surface could result; and (3) if the use of existing roads will contribute additional <br />suspended solids to streamflow and runoff, then additional DRMS coal exploration rules <br />pertaining to water quality will apply to all areas of those roads that will result in such <br />additional suspended solids contributions. Further, our Rules require coal exploration be <br />conducted in a manner that minimizes the disturbance of the prevailing hydrologic balance. <br />The Division believes the use of existing private roads as proposed by NECC in their NOI <br />should minimize the impact to the environment and to privately owned lands. <br />Nevertheless, DRMS will ask NECC to amend existing text narrative in its NOI to address <br />repairs of any unanticipated damage caused by NECC to these roads that creates the <br />potential to adversely affect the prevailing hydrologic balance. <br />With regard to your concerns relative to public roads, our Rules do not grant us the <br />autiioiitj to regulate poieiitiai impaCtS nvin traffic related to coal exploration and <br />reclamation activities upon public roads. Concerns with impacts upon public roads from <br />coal exploration traffic should be addressed to the appropriate public road authorities. <br />8. Communicate with Pioneer local office about equipment movements <br />Our agency does not have the authority to request that persons conducting coal exploration <br />activities to coordinate their activities with oil and gas companies or other such persons. <br />Should NECC wish to do so, it will be up to them. <br />9. Statement about "concrete" being used to seal wells <br />The Division will ask NECC to clarify and correct, if necessary, cementing references and <br />to provide more detail regarding cementing and sealing their coal exploration boreholes. <br />10. Plugging of boreholes using COGCC requirements as a guideline <br />NECC is required to seal the exploration boreholes in accordance with our Rule 4.07. <br />Whether NECC follows additional or more stringent protocols would be their decision. <br />11. Gas seep surveys following abandonment of coal exploration boreholes. <br />Our rules do not require persons conducting coal exploration and reclamation activities to <br />conduct gas seep surveys following drill hole abandonment. The Division believes that it <br />could nevertheless be prudent for NECC to do, so we will suggest this on your behalf. <br />12. Baseline gas seep surveys prior to mining. <br />This concern is not associated with current exploration activities. Concerns about baseline <br />gas seep monitoring related to coal mining and subsidence should be presented at such time <br />should NECC present a specific mine plan for an area under an application for a mining <br />permit or an application for a permit revision.