2014-05-28_REVISION - C1996083

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 5/28/2014
• Doc Name: Groundwater Preliminary Adequacy Review
• From: DRMS
• To: Bowie Resources, LLC
• Type & Sequence: PR14
• Email Name: SLB
• Email Name: SB1
• Media Type: D
• Archive: No

William A. Bear
Page 5 of 8
May 28, 2014
We have the following specific comments and questions pertaining to the PR -14 submittal:
Rule 2.04.7 — Hydrology Description
Rule 2.04.7(1) — Ground Water Information
47. Proposed page 2.04 -35 describes up- gradient monitoring wells CWI -DH -60 and CWI -DH -58
which have been monitored since August 2010. The text states that both wells are dry.
Comments on the Annual Hydrologic Reports (AHR) however suggest that the wells are not
currently functional. According to the AHRs, CWI -DH -60 is constructed at a surface elevation
of 7960' and is 1073' deep. According to Vol. III, Ex. 3, CWI -DH -60 is perforated from 1065'
to 1085', but the hole is plugged with cement to 1073'. The same diagram shows the Upper
B -seam interval as being from 1068' -1073' deep at this location. Map 10B shows projected
contours for the potentiometric surface of groundwater in the B -seam. Although the
contours stop before CWI- DH -60, they may be extrapolated to infer that the potentiometric
head at this location would be in the range 7000'- 7100'; we would therefore expect to see a
static water level in the well, (the measured level would provide valuable information to
improve the certainty and scope of the projected potentiometric surface on Map 10B).
For CWI -DH -58 the AHRs give a surface elevation of 8520' and a depth of 1914'. Vol. II, EX. 3
shows multiple perforations over the lower 320' of the hole. The diagram shows the upper
B -seam at a depth of 1640'- 1649'. Map 10B shows the well between the 7000' and 7100'
contours of the B -seam potentiometric surface, so we would expect to encounter water at a
depth of 1420'- 1520'.
To ensure compliance with the currently approved PAP, the two up- gradient groundwater
monitoring points should be made fit - for - purpose or replaced, so that a static water level
can be reliably measured and water quality samples can be collected, per Rule
4.05.13(1)(e). The text should be revised accordingly.
48. Proposed pages 2.04 -35 and -36 describe the water quality as measured by wells 2010 -1B
and 2010 -1SS. The text does not adequately explain the measured parameter values. For
well 2010 -1B the data presented in AHRs suggest that the well was initially contaminated
during construction, but has since (by natural processes or by intervention) reached an
indicating that the well has been contaminated with alkaline grout (Nielsen,
1991) and invalidating the rest of the water quality data.
2010 -1B
10' X 1.5" steel screen within an 8.75" hole. Screened interval is within a 30'
section filled with sand in the upper B -seam coal. Below the screened section
the hole is plugged with cement, and above it is plugged with Bentonite
pellets and then cement to the surface. Monitored quarterly since 11/11. On
completion a pH value of 9.3 was recorded which suggests some
contamination with alkaline material, however the pH dropped to circa
neutral within a year and has been consistently in the range 7.0 -7.3 since
then.
We have the following specific comments and questions pertaining to the PR -14 submittal:
Rule 2.04.7 — Hydrology Description
Rule 2.04.7(1) — Ground Water Information
47. Proposed page 2.04 -35 describes up- gradient monitoring wells CWI -DH -60 and CWI -DH -58
which have been monitored since August 2010. The text states that both wells are dry.
Comments on the Annual Hydrologic Reports (AHR) however suggest that the wells are not
currently functional. According to the AHRs, CWI -DH -60 is constructed at a surface elevation
of 7960' and is 1073' deep. According to Vol. III, Ex. 3, CWI -DH -60 is perforated from 1065'
to 1085', but the hole is plugged with cement to 1073'. The same diagram shows the Upper
B -seam interval as being from 1068' -1073' deep at this location. Map 10B shows projected
contours for the potentiometric surface of groundwater in the B -seam. Although the
contours stop before CWI- DH -60, they may be extrapolated to infer that the potentiometric
head at this location would be in the range 7000'- 7100'; we would therefore expect to see a
static water level in the well, (the measured level would provide valuable information to
improve the certainty and scope of the projected potentiometric surface on Map 10B).
For CWI -DH -58 the AHRs give a surface elevation of 8520' and a depth of 1914'. Vol. II, EX. 3
shows multiple perforations over the lower 320' of the hole. The diagram shows the upper
B -seam at a depth of 1640'- 1649'. Map 10B shows the well between the 7000' and 7100'
contours of the B -seam potentiometric surface, so we would expect to encounter water at a
depth of 1420'- 1520'.
To ensure compliance with the currently approved PAP, the two up- gradient groundwater
monitoring points should be made fit - for - purpose or replaced, so that a static water level
can be reliably measured and water quality samples can be collected, per Rule
4.05.13(1)(e). The text should be revised accordingly.
48. Proposed pages 2.04 -35 and -36 describe the water quality as measured by wells 2010 -1B
and 2010 -1SS. The text does not adequately explain the measured parameter values. For
well 2010 -1B the data presented in AHRs suggest that the well was initially contaminated
during construction, but has since (by natural processes or by intervention) reached an