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William A. Bear <br />Page 3 of 9 <br />May 19, 2014 <br />West Fork of Terror Creek within the western permit area, as it will be with the Spruce <br />Stomp expansion. <br />10. Revised page 2.04 -38 references the WWE study investigating potential impacts to the West <br />Fork of Terror Creek. The WWE study was not included in the revision application materials, <br />nor is it in the currently approved permit application package. Please include a proposal to <br />incorporate the 2013 WWE study report as an appendix in the permit application package. <br />11. Please update the flow data for stream site (SW -05) on revised page 2.04 -48 to include the <br />most recent monitoring data - the table submitted provides data through 2009, but the <br />annual reports submitted by BRL report monitoring data for this site through 2013. <br />12. Revised page 2.04 -48 appears to have an error in the description of Stevens Gulch, which is <br />perennial. Although this language is not proposed for revision, it should probably be <br />clarified. Please revise the second paragraph of page 2.04 -48 to remove or revise the <br />statement that flows in Stevens Gulch occur in response to snowmelt and precipitation <br />events. <br />13. The application materials submitted by BRL do not adequately address the baseline surface <br />water information requirements of Rule 2.04.7(2). <br />a. For the West Fork of Terror Creek. The data collected at upstream site SW -12 is limited <br />to three months of data, as opposed to the twelve consecutive months required to <br />identify seasonal variations. No data was provided for site SW -1. Please update Exhibit <br />3 of Volume 111 to provide complete baseline data for the upstream and downstream <br />locations on the West Fork of Terror Creek, sufficient to identify seasonal variations, in <br />accordance with Rule 2.04.7(2)(b) and the Division's "Guidelines for the Collection of <br />Baseline Water Quality and Overburden Geochemistry Data" document. <br />b. Data for springs, seeps and ponds also does not cover a twelve month period. Please <br />update Exhibit 3 of Volume 111 to provide complete baseline data for the springs, seeps, <br />and ponds in the Spruce Stomp expansion area, sufficient to identify seasonal <br />variations, in accordance with Rule 2.04.7(2)(b) and the Division's "Guidelines for the <br />Collection of Baseline Water Quality and Overburden Geochemistry Data" document. <br />c. Page 2.04 -54 identifies four unnamed ephemeral gulches and two ephemeral ditches <br />tributary to Terror Creek, but no baseline data has been provided for these gulches and <br />ditches. Please update Exhibit 3 of Volume 111 to provide complete baseline data for <br />the springs, seeps, and ponds in the Spruce Stomp expansion area, sufficient to <br />identify seasonal variations, in accordance with Rule 2.04.7(2)(b) and the Division's <br />"Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry <br />Data" document. <br />Rule 2.04.7(3) — Alternative Water Supply Information <br />