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Susan Burgmaier -14- July 10, 2014 <br />justification the difficulty and expense of installing such wells. The Division acknowledges <br />that deep bedrock groundwater monitoring wells are both technically challenging and <br />relatively expensive to install, however monitoring wells at depths exceeding 2000' are by <br />no means unprecedented (Hanson, 2001). Sampling methods may also be complicated by <br />the depth (Aller, 1991), but the depth at which a bailer can sample is limited only by the <br />length of the cable and the power of the winch. Indeed, as noted above, CWI -DH -58 is <br />drilled to 1914' and may realistically expect to encounter water at 1500' if properly <br />restored to working order. Please suggest either: replacement groundwater <br />monitoring points, a viable alternative to their installation (perhaps through the <br />development of a groundwater model), or compelling evidence as to why neither <br />alternative is appropriate in this specific context. <br />BRL - BRL has agreed to the installation of two down gradient points of compliance. <br />50. DRMS - On proposed page 2.04 -38 the text reads: "The areas of the colluvial- alluvial <br />sediments in Hubbard Creek and Terror Creek lie below the coal seam to be mined." <br />Please revise the text to read: "...above..." <br />BRL - The change was made to page 2.04 -38. <br />Rule 2.05.6(3) - Protection of the Hydrological Balance <br />51. DRMS - The currently approved Probable Hydrologic Consequences (PHC) text states <br />that the underground mining operation may impact the groundwater in the Mesaverde <br />Formation. The Hydrologic Monitoring Plan (from currently approved page 2.05 -116) <br />continues to describe drill holes 2010 -113 and 2010 -1SS without reference to the fact that <br />they are to be mined through. Please revise the text to describe planned changes to the <br />Hydrologic Monitoring Plan. <br />BRL - Currently approved permit page 2.05 -116 is PR -14 page 2.05 -123. Changes to the <br />monitoring plans were added to page 2.05 -124. <br />52. DRMS - PR -14, as proposed, has no provision to replace groundwater monitoring points <br />2010 -113 and -1SS. As such, it would not be possible for the operator to monitor the impacts <br />of mining on subsurface water within or adjacent to the permit area. Furthermore, at the <br />time of a future bond release application, it would not be possible for the Division to make <br />the finding (as required by Rule 3.03.2 (2)) as to "whether pollution ofsurface orsubsurface <br />water is occurring, the probability offuture occurrence ofsuch pollution, and the estimated <br />cost of abating such pollution." <br />a. Please propose a means by which down - gradient groundwater maybe monitored <br />(or a well- constrained model) to allow BRL and the Division to monitor and <br />evaluate the impacts of mining on groundwater that is likely to be affected by the <br />proposed new mining (the B -seam and the strata above the B- seam). <br />