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Jason Musick -2- May 11, 2015 <br />BRL - It is agreed the quality in DH -49 has degraded over time. The monitoring point has been <br />incorrectly classified as impacted by mining. DH -49 has not been impacted by mining. It is <br />located outside the D -Seam and B -Seam subsidence zone. Revised Figure No. 141 is attached. <br />The summary on page 4 of the report states that alluvial well monitoring during the 2013 <br />sampling season provides results consistent with baseline information provided in the permit <br />application, showing no adverse impact to groundwater intercepting wells AW -16 and AW -17. <br />Based on the data, it would appear that there are several instances where monitoring data <br />indicates degradation over baseline values at wells AW -1, AW3, AW -5, AW -6, AW -7, AW -1 1, <br />AW -12, and AW -14. While this degradation is consistent with the predictions of impacts to the <br />hydrologic balance in the approved permit application, the sampling data does show a departure <br />from baseline that should be illustrated as such. Please revise the discussion of the alluvial well <br />monitoring to include a comparison of the 2013 monitoring results to baseline conditions. <br />BRL - A revised AHR narrative is enclosed. The discussion regarding the alluvial wells was revised <br />beginning on page 4 of the narrative. <br />6. Page 2.05 -127 of the approved permit application package states that the small area exemptions <br />shown on Map 20 will be monitored quarterly, and that BRL will use its best efforts to obtain <br />samples. To date, starting with the 1997 AHR, no samples have been collected at any of the <br />small area exemption sites. Please provide information on the efforts BRL has made to sample <br />these sites, including a discussion of how BRL determines when samples should be obtained. <br />BRL - BRL missed the opportunity to obtain samples from the unit train loadout area SAES when <br />the flows were directed through silt fences. The silt fences are no longer required at the unit <br />train loadout (SAES 1 thru 9) based on quality of vegetation. The run -off from these SAES now <br />likely exhibits sheet flow across vegetated areas so future sample collection from these SAES will <br />be futile. Run -off from the remaining SAES is trapped behind lengthy lines of straw bales and or <br />silt fences. It is unlikely BRL will be able to obtain concentrated flow or any flow from these <br />SAES. <br />Sincerely, <br />J. E. S-Mv � <br />J. E. Stover, P.E. <br />Consulting Engineer <br />Cc: Bill Bear, Bowie Resources, LLC (electronically) <br />Paonia Public Library <br />Bureau of Land Management (electronically) <br />US Forest Service (electronically) <br />