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2014-07-11_REVISION - C1996083 (2)
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2014-07-11_REVISION - C1996083 (2)
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Last modified
8/24/2016 5:45:41 PM
Creation date
7/11/2014 2:51:23 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
7/11/2014
Doc Name
Adequacy Response #1
From
J.E. Stover & Associates, Inc
To
DRMS
Type & Sequence
PR14
Email Name
SLB
Media Type
D
Archive
No
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Susan Burgmaier -13- July 10, 2014 <br />Rule 2.04.7 - Hydrology Description <br />Rule 2.04.7(1) - Ground Water Information <br />47. DRMS - Proposed page 2.04 -35 describes up- gradient monitoring wells CWI -DH -60 and <br />CWI -DH -58 which have been monitored since August 2010. The text states that both wells <br />are dry. Comments on the Annual Hydrologic Reports (AHR) however suggest that the <br />wells are not currently functional. According to the AHRs, CWI -DH -60 is constructed at a <br />surface elevation of 7960' and is 1073' deep. According to Vol. I1I, Ex. 3, CWI -DH -60 is <br />perforated from 1065' to 1085', but the hole is plugged with cement to 1073'. The same <br />diagram shows the Upper B -seam interval as being from 1068' -1073' deep at this location. <br />Map 10B shows projected contours for the potentiometric surface of groundwater in the 13- <br />seam. Although the contours stop before CWI- DH -60, they may be extrapolated to infer that <br />the potentiometric head at this location would be in the range 7000'- 7100'; we would <br />therefore expect to see a static water level in the well, (the measured level would provide <br />valuable information to improve the certainty and scope of the projected potentiometric <br />surface on Map 1013). <br />For CWI -DH -58 the AHRs give a surface elevation of 8520' and a depth of 1914'. Vol. II, EX. <br />3 shows multiple perforations over the lower 320' of the hole. The diagram shows the <br />upper B -seam at a depth of 1640'- 1649'. Map 10B shows the well between the 7000' and <br />7100' contours of the B -seam potentiometric surface, so we would expect to encounter <br />water at a depth of 1420'- 1520'. <br />To ensure compliance with the currently approved PAP, the two up- gradient <br />groundwater monitoring points should be made fit- for - purpose or replaced, so that a <br />static water level can be reliably measured and water quality samples can be <br />collected, per Rule 4.05.13(1)(e). The text should be revised accordingly. <br />BRL - BRL will be working on well rehabilitation within the next two months. <br />48. DRMS - Proposed pages 2.04 -35 and -36 describe the water quality as measured by <br />wells 2010 -113 and 2010 -1SS. The text does not adequately explain the measured <br />parameter values. For well 2010 -113 the data presented in AHRs suggest that the well was <br />initially contaminated during construction, but has since (by natural processes or by <br />intervention) reached an equilibrium state from which future changes may be observed. <br />The data for well 2010 -1SS suggest that the well was poorly constructed rendering the <br />water quality data invalid. Please revise the text to provide a more complete <br />discussion of these wells. Since well 2010 -1SS is due to be mined through in 2015 it is <br />perhaps unreasonable to require it to be re- drilled at this moment in time, however it must <br />be stressed that the useful information provided by this well was extremely limited. <br />BRL - Pages 2.04 -35 and 36 were revised as requested. <br />49. DBMS - On proposed page 2.04 -36 the text states that "the PR -14 mine plan area in <br />federal coal lease COC -75916 will not have down gradient monitoring wells ", citing as <br />
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