2010-12-23_APPLICATION CORRESPONDENCE - C2010089

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C- 2010 -089 PAR Part 1 23- Dec -2010 New Horizon North Mine Page 9 of 21 4. A copy of the 1979 survey (revised January 17, 1980) has been included with the application, as has a copy of the 1984 study by High Plains Consultants. However, the two reports have not been numbered as attachments, and are not referenced in the Table of Contents. Please modify the Table of Contents to include references to the 1980 and 1984 reports as attachments. 2.04.5 — General Description of Hydrology and Geology 1. In the second paragraph on page 4 of Section 2.04.5 there is an incomplete sentence or an extra space that needs to be corrected. 2. Under the discussion of Significance of Groundwater on pages 6 and 7 the information presented is from 1970 and focuses on historic use. This seems somewhat outdated and should be clarified with reference to present use. In Section 2.04.7 pages 11 -13 there is a discussion on present and potential use of groundwater, which seems more appropriate. Please add a brief discussion to the significance of groundwater section that references the present and potential use of groundwater and whether the historic consumptive use presented in Table 2.04.5 -2 is reflective of current conditions. 2.04.6 — Geology Description 2.04.6 0) — General Requirements 1. On Figure 2.04.6 -1 General Columnar Section, there is an incorrect reference to the Burro Canyon Shale. The Burro Canyon is a Formation of Cretaceous age as opposed to a Member of the Jurassic age Morrison Formation and is stratigraphically above the Brushy Basin Member of the Morrison Formation. Please correct Figure 2.04.6 -1. 2.04.6 (2) — Surface Mining Rule 2.04.6(2) requires analyses of the coal seam, including, but not limited to, an analysis of the sulfur, pyrite, and marcasite content. In the permit text there are inferences made as to the pyrite and marcasite content visible in core samples but no analyses were provided. Further our Division Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data (1982) recommends that sulfur analyses be broken out into % Pyritic Sulfur, Sulfate Sulfur, and Organic Sulfur in addition to Total Sulfur analysis. The reason for this is to be able to determine the Acid Mine Drainage potential of the replaced spoil material. In Table 2.04.6 -1 Coal Analyses and table 2.04.6 -2 Overburden Analyses of the application, only Total Sulfur wt% is provided. Pursuant to Rule 2.04.6(2)(b)(i)(E), and the Division's "Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data" (Table 5 — Overburden Chemistry), please provide analysis information on the breakdown of the total sulfur, including sulfate, organic, pyritic and marcasite sulfur. 2. In the second paragraph of page 9 (fifth sentence) "...hole drilled..." should be plural "holes drilled ". The footnote to Table 2.04.6 -2 indicates that trace elements were analyzed by EPA Methods 3252/6020. This should read EPA Methods "3052/6020 ".