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William A. Bear <br />Page 7 of 8 <br />May 28, 2014 <br />impacts of mining on groundwater that is likely to be affected by the proposed new <br />mining (the B -seam and the strata above the B- seam). <br />b. In order to forestall some of the well construction issues that have blighted other <br />groundwater monitoring points please propose a detailed plan for the construction of <br />any new wells. <br />c. Please also address the need or otherwise to establish a groundwater point of <br />compliance in the B -Seam and the sandstone above the B -Seam, based on the <br />provisions of Rule 4.05.13 and Regulation 41, as promulgated by the Water Quality <br />Control Commission. The archive shows that there was discussion in 2008 to the effect <br />that that BRL intended to go to the WQCC to have the perched and coal aquifers <br />classified as "Limited Use and Quality ", which would preclude the need for a point of <br />compliance. In the absence of such a specified classification the Division is under the <br />impression that the interim narrative standards of Regulation 41 apply. <br />53. On currently approved page 2.05 -110 the text states that the Bowie No. 2 mine is currently <br />experiencing an inflow of approximately 700 gpm. This does not appear to be consistent <br />with the most recent AHR. Please review this section and update with a narrative <br />documenting mine inflows over time. <br />54. On currently approved page 2.05 -116 the text refers to data that the Division feels should <br />be discounted (or at least qualified), as discussed above. Please revise the text with <br />reference to point (48) of this letter. <br />55. On proposed page 2.05 -118 the text was revised to refer to the 2009 CHIA produced by the <br />Division (further references are made on pages 2.05 -120 and 2.06 -3). In principle this is <br />discouraged, since the CHIA documents are written by Division specialists, based on <br />information contained in the PHC sections of individual mine permits; by citing the CHIA in a <br />PHC an element of self- reference is introduced. It would be preferable for BRL to devise a <br />method of estimating the discharge volume of refuse and coal leachate independent of the <br />Division so that the method may be assessed as the CHIA comes to be revised (this is <br />currently overdue). <br />Please revise the text to remove reference to the CHIA. Please provide a clear description <br />of the methodology and assumptions underpinning the estimate of leachate discharge <br />volumes (taking into account the fact that the infiltration rate through a coal stockpile is <br />likely to be much higher than that through a compressed refuse pile). The subsequent <br />tables estimating the PHC to the North Fork of the Gunnison should also be updated <br />accordingly. <br />56. On proposed page 2.05 -118, data from AW -2 has been removed from the baseline water <br />quality summary. Minimum values for several other wells have increased. Also in that table, <br />there appears to be errors in the calculation of some of the average values. Please clarify <br />why the data in the baseline table is subject to change and review the values in the table, <br />updating as necessary. <br />