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William A. Bear <br />Page 6 of 8 <br />May 28, 2014 <br />equilibrium state from which future changes may be observed. The data for well 2010 -1SS <br />suggest that the well was poorly constructed rendering the water quality data invalid. <br />Please revise the text to provide a more complete discussion of these wells. Since well <br />2010 -1SS is due to be mined through in 2015 it is perhaps unreasonable to require it to be <br />re- drilled at this moment in time, however it must be stressed that the useful information <br />provided by this well was extremely limited. <br />49. On proposed page 2.04 -36 the text states that "the PR -14 mine plan area in federal coal <br />lease COC -75916 will not have down gradient monitoring wells ", citing as justification the <br />difficulty and expense of installing such wells. The Division acknowledges that deep bedrock <br />groundwater monitoring wells are both technically challenging and relatively expensive to <br />install, however monitoring wells at depths exceeding 2000' are by no means <br />unprecedented (Hanson, 2001). Sampling methods may also be complicated by the depth <br />(Alter, 1991), but the depth at which a bailer can sample is limited only by the length of the <br />cable and the power of the winch. Indeed, as noted above, CWI -DH -58 is drilled to 1914' <br />and may realistically expect to encounter water at 1500' if properly restored to working <br />order. Please suggest either: replacement groundwater monitoring points, a viable <br />alternative to their installation (perhaps through the development of a groundwater <br />model), or compelling evidence as to why neither alternative is appropriate in this specific <br />context. <br />50. On proposed page 2.04 -38 the text reads: "The areas of the colluvial- alluvial sediments in <br />Hubbard Creek and Terror Creek lie below the coal seam to be mined." Please revise the <br />text to read: "...above..." <br />Rule 2.05.6(3) — Protection of the Hydrological Balance <br />51. The currently approved Probable Hydrologic Consequences (PHC) text states that the <br />underground mining operation may impact the groundwater in the Mesaverde Formation. <br />The Hydrologic Monitoring Plan (from currently approved page 2.05 -116) continues to <br />describe drill holes 2010 -1B and 2010 -1SS without reference to the fact that they are to be <br />mined through. Please revise the text to describe planned changes to the Hydrologic <br />Monitoring Plan. <br />52. PR -14, as proposed, has no provision to replace groundwater monitoring points 2010 -113 <br />and -1SS. As such, it would not be possible for the operator to monitor the impacts of <br />mining on subsurface water within or adjacent to the permit area. Furthermore, at the time <br />of a future bond release application, it would not be possible for the Division to make the <br />finding (as required by Rule 3.03.2(2)) as to "whether pollution of surface or subsurface <br />water is occurring, the probability of future occurrence of such pollution, and the estimated <br />cost of abating such pollution." <br />a. Please propose a means by which down - gradient groundwater may be monitored (or <br />a well- constrained model) to allow BRL and the Division to monitor and evaluate the <br />