2011-04-08_PERMIT FILE - C1981012A ‎(8)‎

• Permit No: C1981012A
• IBM Index Class Name: Permit File
• Doc Date: 4/8/2011
• Section_Exhibit Name: SECTION 2.04 APPLICATION FOR PERMIT FOR SURFACE OR UNDERGROUND MINING ACTIVITIES
• Media Type: D
• Archive: Yes

Average chemical analyses of the Allen, Apache, and Maxwell Seams are provided in Table
4A. Average moisture content ranges from 1 to 2% and thermal content ranges from 11,000 to 13,500
Btu/lb. A sulfur form analysis performed on the Allen Seam by Commercial Testing and Engineering
in 1981 (Table 5) indicated a total sulfur content of 0.49 %, which consisted of pyritic sulfur of 0.06%
and organic sulfur of 0.43 %. Because pyritic sulfur is the species of concern and because it is a
relatively small proportion of the total sulfur, sulfur forms do not appear to be a significant
environmental concern.
Table 4A. Average Chemical Analysis of the Coal Seams (Raw, arb)
Seam
Volatile Matter
Fixed Carbon
Ash
Sulfur
Allen
32.0
46.6
18.2
0.47
Apache
31.6
50.9
14.6
0.50
Maxwell
29.8
42.9
23.8
0.46
An average of 11 analyses of the Allen seam is as follows:
Moisture
0.7
Ash
8.5
Volatile Matter
37.8
Sulfur
0.49
Fixed carbon
53.0
Btu
13,740
A sulfur form analysis of the Allen coal seam has been regarded as typical rather than
representative, see Table 5, Sulfur Form Analysis. The analysis reflects the dominant organic
sulfur species to be the species. Since the product is removed, and the single sample correlates with
the historical proximate analyses above, sulfur forms in the product should be of negligible
environmental concern. No further analyses are contemplated.
No significant aquifers were encountered during previous mining in the New Elk Mine and
none are expected in the slopes at the Bates Portal. Although sandstones are a dominant lithology in
the mine area and generally are regarded as being significant aquifers, Raton Formation sandstones
are clay - filled and usually do not yield water in appreciable quantities. Permeability testing
performed reflects the impermeable character of the sandstone units (refer to Page 17 of Exhibit 8
(Hydrology and Geology Information - TR55 Addendum).
Given the heterogeneous distribution of the sediments enclosing the coal, Exhibit 9,
Overburden and Underburden Analysis, displays a reasonable correlation of chemical risks incident
to mining in the separate Allen and Maxwell environments. The Exhibit reflects the geochemical
controls of the quality of water developed during mining and demonstrates a buffer capacity sufficient
to limit concentrates of trace metals. That point is further confirmed in the characterization of the
quality of ground and surface waters presented in Exhibit 8, Hydrology and Geology Information, and
the evaluation of subsequent data, Exhibit 10, Water Quality Analysis, collected since the hydrology
study was completed.
TR -55 2.04 -10
•
01/20/11