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William A. Bear <br />Page 6 of 9 <br />May 19, 2014 <br />of any perennial stream, requiring that the area be designated a stream buffer zone and <br />that buffer zone markers (per Rule 4.02) be installed and maintained. Accordingly, the <br />Division will require BRL to establish a stream buffer zone of 200' from the normal high <br />water line of the West Fork of Terror Creek. Additionally, prior to any surface disturbance in <br />the vicinity of the West Fork of Terror Creek, BRL must install the stream buffer zone <br />markers required by Rule 4.02. <br />27. Please update Maps 09,15-1,15-2,15-3, and 15 -4 to include the designated stream buffer <br />zones required by Rule 4.05.18 for all perennial streams and intermittent streams or <br />ephemeral streams draining an area greater than one square mile within the permit area <br />boundary. <br />28. Revised pages 2.05 -104 and 2.05 -172 commit to the establishment of at least two <br />subsidence monitoring gridlines across the West Fork of Terror Creek. BRL does not specify <br />the locations of these proposed gridlines. Please provide the locations of these gridlines on <br />Map 278. Please also revise the text to indicate that the initial survey will be conducted <br />and the data submitted to the Division at least six months prior to longwall mining <br />beneath the area, and semi - annually thereafter. <br />29. Revised page 2.05 -108 discusses water rights within the permit area and summarizes their <br />relationship to the mining area, and whether there are any anticipated impacts from mining <br />to those water rights. The Terror Ditch is not discussed in this section, nor are potential <br />impacts to the ditch discussed in Section 2.04.7(3). Please revise page 2.05 -108 to include <br />a discussion on what, if any, impacts BRL anticipates occurring on the Terror Ditch as a <br />result of the mining planned in the PR -14 expansion area. <br />30. Please update the Probable Hydrologic Consequences section of the permit, beginning on <br />revised page 2.05 -115, to include a discussion on the potential impacts from undermining <br />to the West Fork of Terror Creek. <br />31. Because the undermining of the West Fork of Terror Creek may result in flow interruptions, <br />potentially impacting the rights of users of the Terror Ditch (Rule 2.05.6(3)(a)(ii)), the <br />Division will require more frequent monitoring of flow conditions on the West Fork of <br />Terror Creek. More frequent monitoring will ensure that the monitoring plan is based on <br />and appropriate for the probable hydrologic consequences determination, as required by <br />Rule 2.05.6(3)(b)(iv). Please update pages 2.05 -126 and 2.05 -169 to commit to weekly <br />monitoring of field parameters on the West Fork of Terror Creek during active subsidence, <br />as each panel passes beneath the creek, and monthly monitoring of field parameters <br />three months prior to and six months following extraction. Quarterly monitoring, as <br />proposed on revised page 2.05 -126 is appropriate three months before and six months after <br />mining has advanced into and beyond the projected angle of draw beneath the creek. <br />