2014-10-06_REVISION - C1996083 (3)

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Susan Burgmaier -2- October 3, 2014 b. In response to the Division's request for complete baseline data for springs, seeps, and ponds, BRL provided one year of baseline data for springs, seeps, and ponds in the Spruce Stomp lease area. Revised page 2.05 -129 indicates that Spring 6 -1, located on the south side of the West Fork of Terror Creek (and shown on Map 9) will be monitored. There does not appear to be any baseline data submitted for Spring 6 -1. Please provide baseline data required by Rule 2.04.7(2) (b) for this spring, or explain why the data has not been provided. BRL - Spring 6 -1 was first monitored August 2, 1983. It has been monitored quarterly for the last four years 2010, 2011, 2012 and 2013. The monitoring data is shown in the annual reports. It has also been monitored quarterly during 2014. It does not appear that BRL has provided a response to this item, as we did not locate any baseline data for any of the ephemeral gulches in the Spruce Stomp area and BRL did not mention any monitoring plans. 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 III to provide the suggested baseline data for the ephemeral gulches in the Spruce Stomp expansion, or acknowledge the requirement to provide the required one year of baseline data on any ephemeral gulches to be affected by future surface disturbances prior to that disturbance. BRL - Data are presented for nine ephemeral channels in the Spruce Stomp expansion area. The ephemeral channels area labeled EPH -1 through EPH -9 on Map 9. A short discussion on monitoring the ephemeral channels was added to Page 2.05- 126. 25. BRL indicated in its September 12, 2014 response letter that it is negotiating with Terror Creek LLC to purchase the Terror Creek Loadout to be permitted as a coal mine waste disposal area. It remains uncertain as to whether the property will ultimately be permitted as a waste disposal area, and if so, whether the property would provide ample storage space for the material to be generated by the Spruce Stomp reserves.