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 -3- September 2, 2014
by the guideline. BRL should also observe and document flow conditions of the gulches when
conducting regular quarterly monitoring of the remaining surface water sites to establish
baseline conditions. BRL should endeavor to sample any potentially affected gulches now,
during storm events, to prevent delays in permitting surface disturbance in the future. Please
update Exhibit 3 of Volume 111 to provide the suggested baseline data for the ephemeral
gulches in the Spruce Stomp expansion area as soon as it becomes available.
BRL - BRL will provide the baseline data requested above after the September monitoring is
complete.
Rule 2.04.7(3) — Alternative Water Supply Information
14. Issue resolved; BRL revised page 2.04 -58 as requested.
15. Revised page 2.04 -63 indicates that the augmentation plan for replacement water will
be decreed, and BRL noted that approval of the augmentation plan will be a stipulation in the
BLM lease approval. Please provide a copy of the proposed augmentation plan and the status
of the plan application /approval, so that we can better determine whether it would be
appropriate for the Division to consider stipulating approval of the augmentation plan in our
approval of PR -14.
BRL - The water augmentation plan is attached. The plan was submitted late July or early
August. The best case approval time for the plan is one year.
16. Please update revised page 2.04 -119, water depletion and Section 7 summary to
reflect the recent expansion of Ponds D and J.
BRL - The normal surface area for Pond D has not been changed. The normal surface area for
Pond J decreased. Amended pages 2.04 -120, 123 and 124 are enclosed.
17. Issue resolved; BRL revised Map 09 as requested.
Rule 2.04.9 — Soils Resource Information
18. Issue resolved; BRL provided the requested description.
Rule 2.04.10 —Vegetation Information
19. Issue resolved; the Division will place a stipulation on approval of PR -14 stating that no
surface disturbance can occur on any Spruce Stomp lease land prior to submittal and approval
of baseline vegetation data.
20. BRL has drilled more than 75 gob vent boreholes to support its current mining
operations (Drill Holes — Original Ground Slope Information, Permit page 2.05 -44 & 45) and the
permit states that "three or more gob vent boreholes are required over each longwall panel"
(page 2.05 -43). While no disturbance in the Spruce Stomp lease area is being proposed at this
time, the Division anticipates that more gob vent boreholes will be needed in future operations
within the Spruce Stomp expansion area. Please take note, that vegetation data that meet the
standards of Rule 2.04.10 will need to be submitted to and approved before future