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2.06 REQUIREMENTS FOR PERMITS FOR SPECIAL CATEGORIES OF <br />MINING <br />2.06.8 Surface Coal Mining and Reclamation Operations on Areas, or Adjacent to <br />Areas, Including Alluvial Valley Floors. <br />(1) ERO prepared an Alluvial Valley Report during 2010. Their report is <br />presented in Volume I, Tab 14. The report makes a case that the proposed <br />permit and adjacent area are not alluvial valley floors. <br />For the purposes of this discussion, the proposed permit and adjacent area <br />are considered Undeveloped Rangeland, Fish & Wildlife and Industrial <br />which are not significant to farming. As shown in the soils report in Exhibit 7, <br />five out of six topsoil samples (TLO -2, TLO -3, TLO-4, TLO -5 and TLO -6) <br />indicate the top six inches of soil in the undeveloped rangelands are very <br />strongly saline with SAR values of 59.6, 57.1, 21.8, 58.2 and 62.3 <br />respectively. Additionally, the majority of the area that will be disturbed is <br />barren land previously used as evaporation ponds and landfarm areas for <br />refinery- generated waters and waste materials. <br />The operation will not materially damage the quantity or quality of water in <br />surface or ground water systems that supply those alluvial valley floors. <br />Discussion in Section 2.05.6 indicates leachate from the coal pile will lower <br />conductivity and TDS concentrations in the groundwater in the vicinity of the <br />coal pile and the groundwater. <br />Section 2.05.6 also indicates sediment pond discharge will not occur and <br />therefore, will not have an impact on the quality of water in Reed Wash with <br />regard to salt content. <br />Aside from the issue of whether the property qualifies as an AVF, all of <br />the proposed operations will be at the ground surface and would not <br />impair the existing and future hydrologic function of the property. <br />2.06.9 Augering <br />The Applicant does not plan to conduct augering operations, therefore no <br />response is required for this section. <br />Permit Application 2.06-2- 12/11 <br />