2014-09-09_REVISION - C1996083 ‎(3)‎

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 9/9/2014
• Doc Name: Adequacy Response #2
• From: J.E. Stover & Associates, Inc
• To: DRMS
• Type & Sequence: PR14
• Email Name: SLB
• Email Name: DIH
• Media Type: D
• Archive: No

Susan Burgmaier -2- September 2, 2014
BRL - The coal lease will be provided to DRMS when it is received.
Rule 2.04.4 —Cultural and Historic Resource Information
6. Issue resolved; no response to the Division's comment was required from BRL.
7. Issue resolved, BRL revised the pagination of revised page 2.04 -12, and retained existing
page 2.04 -13.
Rule 2.04.6 — Geology Description
8. The Division requested that BRL update Maps 08 and 08A to include stratigraphy and
structure information for the PR -14 expansion area, as required by Rules 2.04.6(1) and (3). BRL
revised Maps 8 and 8A to include data from drill hole SS -9. Does BRL have any data from the
exploration holes (SS -2, SS -3, SS -4A and SS -4B) drilled under NOI X- 2005 - 217 -10? If data is
available, it should be added to Maps 8 and SA for a more complete representation of the
permit area and affected area being added with PR -14. Also, it appears that the scale is
incorrect for Cross Section B -B'; the distance between USS -G -14 and SS -9 does not appear to be
accurate. Please verify the scale of Cross Section 8 -B' on Map 08 -A and revise as necessary.
BRL - The distance between USS -G -14 and SS -9 was corrected on Map 08A cross Section D -D'.
SS -2 was added to section A -A shown on Map 08. SS -2 was added to the discussion on pages
2.05 -122 and 123.
Rule 2.04.7 — Hydrology Description
Rule 2.04.7(2) — Surface Water Information
9. Issue resolved; BRL updated page 2.04 -12 as requested.
10. Issue resolved; BRL incorporated the WWE study as Tab 23 of Volume 1116.
11. Issue resolved; BRL updated the flow data for stream site (SW -05).
12. Issue resolved; BRL revised page 2.04 -48 as requested.
13. a. In response to the Division's request for complete baseline data for the West
Fork of Terror Creek, BRL indicated that baseline data collection is ongoing. Please update
Exhibit 3 of Volume 111 to provide complete baseline data for the West Fork of Terror Creek as
soon as it becomes available. The Division cannot grant approval for PR -14 without the
baseline data required by Rule 2.04.7(2)(b).
b. In response to the Division's request for complete baseline data for springs, seeps, and
ponds, BRL indicated that baseline data collection is ongoing. Please update Exhibit 3 of
Volume Ill to provide complete baseline data for the springs, seeps, and ponds in the Spruce
Stomp expansion area as soon as it becomes available. The Division cannot grant approval for
PR -14 without the baseline data required by Rule 2.04.7(2)(b).
C. In response to the Division's request for complete baseline data for the ephemeral
gulches, BRL asked whether baseline information would be necessary for the ephemeral
gulches. The Division's Guidelines for the Collection of Baseline Water Quality and Overburden
Geochemistry Data suggest that ephemeral streams be sampled twice a year (snow melt and a
storm event), and that flow measurement frequency should be dealt with on an individual
basis. If these gulches will receive drainage from areas proposed for future surface disturbance
(gob vent boreholes and /or roadways, BRL will need to collect water quality data as suggested