2014-09-18_REVISION - C1996083 (2)

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Susan Burgmaier -2- September 12, 2014 Rule 2.04.6 —Geology Description 8. Issue resolved Rule 2.04.7 — Hydrology Description Rule 2.04.7(2) — Surface Water Information 13. BRL has not yet responded to this issue; BRL indicated the data collection would be complete in September. 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 111 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 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 - The September monitoring will complete the required year of baseline monitoring. Monitoring is scheduled for the week of the 19th. Rule 2.04.7(3) — Alternative Water Supply Information 15. BRL provided a copy of the proposed augmentation plan as requested, and indicated that the best case scenario on approval of the plan would be roughly one year. The Division will place a stipulation requiring approval of the augmentation plan before any mining in the Spruce Stomp lease on its approval of PR -14.