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Susan Burgmaier -15- July 10, 2014 <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 <br />construction of 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 <br />Quality Control Commission. The archive shows that there was discussion in 2008 to <br />the effect that that BRL intended to go to the WQCC to have the perched and coal <br />aquifers classified as "Limited Use and Quality ", which would preclude the need for a <br />point of compliance. In the absence of such a specified classification the Division is <br />under the impression that the interim narrative standards of Regulation 41 apply. <br />BRL - BRL has agreed to the installation of two down gradient points of compliance. See <br />pages 2.05-124,131 and Map 9. <br />53. DRMS - On currently approved page 2.05 -110 the text states that the Bowie No. 2 mine <br />is currently experiencing an inflow of approximately 700 gpm. This does not appear to be <br />consistent with the most recent AHR. Please review this section and update with a <br />narrative documenting mine inflows over time. <br />BRL - The referenced text regarding the 700 gpm flow is now on PR -14 page 20.5 -117. The <br />700 gpm figure is stated in past tense. <br />54. DRMS - On currently approved page 2.05 -116 the text refers to data that the Division <br />feels should be discounted (or at least qualified), as discussed above. Please revise the <br />text with reference to point (48) of this letter. <br />BRL - Currently approved permit page 2.05 -116 is PR -14 page 2.05 -123. Statements were <br />added to qualify the quality data. <br />55. DRMS - On proposed page 2.05 -118 the text was revised to refer to the 2009 CHIA <br />produced by the Division (further references are made on pages 2.05 -120 and 2.06 -3). In <br />principle this is discouraged, since the CHIA documents are written by Division specialists, <br />based on information contained in the PHC sections of individual mine permits; by citing <br />the CHIA in a PHC an element of self- reference is introduced. It would be preferable for <br />BRL to devise a method of estimating the discharge volume of refuse and coal leachate <br />independent of the Division so that the method may be assessed as the CHIA comes to be <br />revised (this is currently overdue). <br />Please revise the text to remove reference to the CHIA. Please provide a clear <br />description of the methodology and assumptions underpinning the estimate of <br />leachate discharge volumes (taking into account the fact that the infiltration rate <br />through a coal stockpile is likely to be much higher than that through a compressed <br />refuse pile). The subsequent tables estimating the PHC to the North Fork of the <br />Gunnison should also be updated accordingly. <br />