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William A. Bear <br />Page 3 of 8 <br />August 19, 2014 <br />b. In response to the Division's request for complete baseline data for springs, seeps, and <br />ponds, BRL indicated that baseline data collection is ongoing. Please update Exhibit 3 of <br />Volume 111 to provide complete baseline data for the springs, seeps, and ponds in the <br />Spruce Stomp expansion area as soon as it becomes available. The Division cannot <br />grant approval for PR -14 without the baseline data required by Rule 2.04.7(2)(b). <br />c. In response to the Division's request for complete baseline data for the ephemeral <br />gulches, BRL asked whether baseline information would be necessary for the ephemeral <br />gulches. The Division's Guidelines for the Collection of Baseline Water Quality and <br />Overburden Geochemistry Data suggest that ephemeral streams be sampled twice a <br />year (snow melt and a storm event), and that flow measurement frequency should be <br />dealt with on an individual basis. If these gulches will receive drainage from areas <br />proposed for future surface disturbance (gob vent boreholes and /or roadways, BRL will <br />need to collect water quality data as suggested by the guideline. BRL should also <br />observe and document flow conditions of the gulches when conducting regular <br />quarterly monitoring of the remaining surface water sites to establish baseline <br />conditions. BRL should endeavor to sample any potentially affected gulches now, during <br />storm events, to prevent delays in permitting surface disturbance in the future. Please <br />update Exhibit 3 of Volume 111 to provide the suggested baseline data for the <br />ephemeral gulches in the Spruce Stomp expansion area as soon as it becomes <br />available. <br />Rule 2.04.7(3) — Alternative Water Supply Information <br />14. Issue resolved; BRL revised page 2.04 -58 as requested. <br />15. Revised page 2.04 -63 indicates that the augmentation plan for replacement water will be <br />decreed, and BRL noted that approval of the augmentation plan will be a stipulation in the <br />BLM lease approval. Please provide a copy of the proposed augmentation plan and the <br />status of the plan application /approval, so that we can better determine whether it would <br />be appropriate for the Division to consider stipulating approval of the augmentation plan <br />in our approval of PR -14. <br />16. Please update revised page 2.04 -119, water depletion and Section 7 summary to reflect <br />the recent expansion of Ponds D and J. <br />17. Issue resolved; BRL revised Map 09 as requested. <br />Rule 2.04.9 —Soils Resource Information <br />18. Issue resolved; BRL provided the requested description. <br />Rule 2.04.10 — Vegetation Information <br />