2014-09-09_REVISION - C1996083 (2)

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William A. Bear Page 3of6 August 19, 2014 16. Issue resolved; BRL revised page 2.04 -120, to reflect the recent expansion of Ponds D and J. Rule 2.05.3 —Operation Plan 25. BRL did not provide a response to this issue: Please provide information on BRL's proposed plans for disposal of the coal processing waste, as required by Rule 2.05.3(8), that will be generated as a result of mining the reserves in the PR -14 expansion area. Rule 2.05.6 — Mitigation of the Impacts of Mining Operations Rule 2.05.6(3) — Protection of the Hydrological Balance 27. Issue resolved; BRL updated Map 9 to depict the stream buffer zones required by Rule 28. Issue resolved; BRL explained the reasoning behind the proposed location of subsidence monitoring stations WT -1 through WT -11, and the explanation is reasonable. 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 agreed that monthly monitoring would suffice during freezing conditions, but indicated 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. The latest revision does not commit to weekly monitoring of high flows when real time data is unavailable. Please revise page 2.05 -126 to include a commitment to weekly monitoring, when real time data is not available, of flow in the West Fork of Terror Creek during high flows as the longwall in Panels 21, 23, 24, 25, and 26 passes beneath the creek. The flow monitoring plan should be: • Real time data when it is available (expecting that it will be unavailable during high flow and freezing conditions). • In the absence of real time data: • High flow: Monthly, increasing to weekly during those periods of undermining (three months prior and six months following extraction) when the West Fork of Terror Creek lies within the predicted angle of draw. • Freezing Conditions: Monthly. • Real time data equipment otherwise inoperable: Weekly. 32. Issue resolved; BRL revised the text on page 2.05 -127 as requested. Rule 2.05.6(6) Subsidence Survey, Subsidence Monitoring, and Subsidence Control Plan