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4. The narrative presented in Section 2.04.5 of the PAP does not appear to provide the requisite <br />information regarding surface water. Please revise this section to include a general discussion <br />of surface water as required by 2.04.5(1). <br />Response - The required surface water discussion has been added Seepages 4 and S. <br />5. Numerous authors and publications are referenced within the text of this section. Please <br />provide a complete list of references at the end of the section in accordance with the <br />requirements of 2.03.3(1). <br />Response -A complete list of references is provided on page 11. <br />2.04.6 - Geology Description <br />2.04.6 1 - General Requirements <br />1. On Figure 2.04.6-1 General Columnar Section, there is an incorrect reference to the Burro <br />Canyon Shale. The Burro Canyon is a Formation of Cretaceous age as opposed to a Member <br />of the Jurassic age Morrison Formation and is stratigraphically above the Brushy Basin <br />Member of the Morrison Formation. Please correct Figure 2.04.6-1. <br />Response - The Figure 2.04.6-1 has been corrected <br />2.046(2) - Surface Mining <br />1. Rule 2.04.6(2) requires analyses of the coal seam, including, but not limited to, an analysis of <br />the sulfur, pyrite, and marcasite content. In the permit text there are inferences made as to the <br />pyrite and marcasite content visible in core samples but no analyses were provided. Further our <br />Division Guidelines for the Collection of Baseline Water Quality and Overburden <br />Geochemistry Data (1982) recommends that sulfur analyses be broken out into % Pyritic <br />Sulfur, Sulfate Sulfur, and Organic Sulfur in addition to Total Sulfur analysis. The reason for <br />this is to be able to determine the Acid Mine Drainage potential of the replaced spoil material. <br />In Table 2.04.6-1 Coal Analyses and table 2.04.6-2 Overburden Analyses of the application, <br />only Total Sulfur wt% is provided. Pursuant to Rule 2.04.6(2)(b)(i)(E), and the Division's <br />"Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry <br />Data' (Table 5 - Overburden Chemistry), please provide analysis information on the <br />breakdown of the total sulfur, including sulfate, organic, pyritic and marcasite sulfur. <br />Response - Peabody coal analyses are included as Appendix Table 2.04.6-4. Coal <br />analyses of samples taken during overburden core sampling are included in Appendix <br />Table 2.04.6-5. <br />2. In the second paragraph of page 9 (fifth sentence) "...hole drilled..." should be plural "holes <br />drilled". <br />Response - Change made <br />3. The footnote to Table 2.04.6-2 indicates that trace elements were analyzed by EPA Methods <br />3252/6020. This should read EPA Methods "3052/6020". <br />Response to First Adequacy Review Page 13