2014-08-19_REVISION - C1996083 - Laserfiche WebLink

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William A. Bear Page 5 of 8 August 19, 2014 within the permit area boundary. BRL indicated that depiction of the stream buffer zones is not required by the rules. Although not required by a specific rule, Rule 2.10.3(1)(1) allows the Division to require "other relevant information... for good cause shown." The Division believes that showing the stream buffer zones on the maps will ensure that stream buffer zones are considered in any future permitting actions for surface disturbance in the vicinity of the streams. This information will be helpful to the Division and BRL in maintaining compliance with Rule 4.05.18 and the specific requirements set forth by the USFS and BLM. Accordingly, we are asking BRL to update the specified maps to depict the stream buffer zones required by Rule 4.05.18. 28. BRL provided the information, as requested. The proposed monitoring frequency for stations WT -1 through WT -17 is acceptable. It is not clear, however, why BRL has placed stations WT -1 through WT -11 over the entries between Panels 24 and 26 as opposed to placing the stations over the longwall panels where subsidence is likely to occur. Please explain the reasoning behind the proposed location of subsidence monitoring stations WT- 1 through WT -11. 29. Issue resolved; BRL revised page 2.05 -108 as requested. 30. Issue resolved; BRL provided the requested discussion. 31. The Division indicated that weekly flow monitoring on the West Fork of Terror Creek would be required as each panel passes beneath the creek. BRL revised pages 2.05 -126 and 2.05- 169 to indicate that flow conditions on the West Fork of Terror Creek would be monitored with real time data, except that monthly monitoring would replace the real time data in freezing or high flow conditions. The Division agrees that monthly monitoring would suffice during freezing conditions, but believes that during active undermining, flow should be observed at least weekly to ensure that BRL is able to quickly resolve any issues resulting in diminution of quantity to users of water in the creek. Please revise page 2.05 -126 to include a commitment to weekly monitoring, when real time data is not available, of field parameters on the West Fork of Terror Creek as the longwaii in Panels 21, 23, 24, 25, and 26 passes beneath the creek. 32. Issue resolved; however, the text on page 2.05 -127, first paragraph, should be revised to clarify that quarterly monitoring was required until Technical Revision No. 59 was approved. There is conflicting information in the paragraph. Rule 2.05.6(6) Subsidence Survey, Subsidence Monitoring, and Subsidence Control Plan 33. Issue resolved; BRL directed the Division to the description of the structure, and updated Map 27 for clarity. 34. Issue resolved; BRL revised pages 2.05 -171 and 2.05 -178 as requested.