Laserfiche WebLink
Jason Musick -2- July 7, 2015 <br />Upper D -Seam or if BRL requests to have these wells terminated from the required <br />monitoring plan, please provide information that will serve as justification for no longer <br />monitoring sites DH -25 and DH -38 for field parameters and full sample suite. <br />BRL - The casing on DH -15 has become pinched along with DH -25 and DH -38. DH -15 is pinched <br />so severely that the depth to water probe will not go down the hole. BRL requests that all <br />three holes be removed from the monitoring program. All three monitoring wells are <br />completed in the D -Seam. The justification for no longer monitoring the three monitoring <br />wells is the fact that sufficient up gradient baseline information is available. DH -15 has <br />complete monitoring data from 6/13/95 through 10/01/2013. DH -25 has complete monitoring <br />data from to 6/13/1995 through 11/22/2002. DH -38 has monitoring data from 2/23/1994 <br />through 12/01/2010. The depth to water probe has been dry or mud covered during most of <br />DH -38's monitoring events. This text was added to page 2.05-124. <br />3. DRMS - According to approved page 2.05-1331, site TC -03-01(B) is completed in the Upper B - <br />Seam and TC -03-02 is completed in the water bearing unit above the B -Seam and serve as <br />downgradiant monitoring wells. Based on the table accompanying the TR -103 cover letter, <br />both sites TC -03-01(B) and TC -03-02 are currently damaged and could not be rehabilitated. <br />These two sites are required to be monitored for field parameters quarterly and a full suite <br />sample will be conducted semi-annually. In order to meet the requirements of Rule 2.05.6(3) <br />and to ensure that the quality of groundwater should not be impacted, stated in the PHC <br />section of the Bowie No. 2 PAP, please provide information addressing which sites will be <br />utilized in place of TC -03-01(B) and TC -01-02 respectfully, to serve as downgradiant <br />groundwater wells for the Upper D -Seam or if BRL requests to have these wells terminated <br />from the required monitoring plan, please provide information that will serve as justification <br />for no longer monitoring these sites for field parameters and full sample suite and <br />replacement wells will not be necessary. <br />BRL - The replacement down gradient wells are 2010-1SS and 2010-113. <br />4. DRMS - A total of 23 monitoring sites are proposed to be temporarily suspended due to the <br />sites not being affected by mining until a date in the future. Based on the water monitoring <br />information which has been collected to date of the sites requested for temporary suspension, <br />the Division agrees to allow BRL to suspend monitoring at the listed 23 sites. However, the <br />Division feels that a commitment to re-initiate monitoring at least one year prior to a site being <br />affected by mining is required. Please provide a revision to the proposed text which includes <br />a commitment to re-initiate the monitoring of each site that is proposed to be temporarily <br />suspended at no later than one year prior to being affected by mining. <br />BRL - The requested text was added to the bottom of page 2.05-130. <br />S. The B -Gulch up, B -Gulch low, C -Gulch up, C -Gulch low, D -Gulch up, and D -Gulch low <br />monitoring sites are requested to be permanently suspended. The B -Gulch low and C -Gulch <br />low sites are located directly above Ponds B and C respectfully. Any discharge from B -Gulch <br />and C -Gulch will be reported to Ponds B and C. The B -Gulch low and C -Gulch low sites provide <br />data as to the quality and quantity of water prior to entering the pond. This information is <br />required prior to removal of a pond or to serve as part of a justification for a pond removal <br />