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Bowie Resources, LLC <br />Page 2 <br />6/24/2015 <br />2. Division's initial comment - According to approved page 2.05 -1331, sites DH -25 and DH -38 are <br />completed in the Upper D -Seam and serve as upgradiant monitoring wells. Based on the table <br />accompanying the TR -103 cover letter, both sites DH -25 and DH -38 are currently active for water <br />level only. These two sites are required to be monitored for field parameters quarterly and a <br />full suite sample will be conducted semi - annually. In order to meet the requirements of Rule <br />2.05.6(3) and to ensure that the quality of groundwater should not be impacted, stated in the <br />PHC section of the Bowie No. 2 PAP, please provide information addressing which sites will be <br />utilized in place of DH -25 and DH -38 respectfully, to serve as upgradiant groundwater wells for <br />the 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 response - The casing on DH -15 has become pinched along with DH -25 and DH -38. DH -15 is <br />pinched so severely that the depth to water probe will not go down the hole. BRL requests that <br />all 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 wells <br />is the fact that sufficient up gradient baseline information is available. DH -15 has complete <br />monitoring data from 6/13/95 through 10/01 /2013. DH -25 has complete monitoring data from <br />6/13/1995 through 11 /22/2002. DH -38 has monitoring data from 2/23/1994 through <br />12/01/2010. The depth to water probe has been dry or mud covered during most of DH -38's <br />monitoring events. The text was added to page 2.05 -124. <br />Division comment - Based on Rule 4.05.13(3)(b), the person who conducts surface or underground <br />mining activities shall continue to monitor surface and groundwater quality and quantity in <br />accordance with the approved plan until disturbed areas have been regraded and stabilized <br />according to this rule, and after cessation of use of underground mine workings. If it is the <br />intention for BRL to not replace these wells with upgradiant monitoring wells for the Upper D- <br />Seam, per Rule 4.05.13(1), the Division cannot approve the permanent suspension of monitoring <br />of wells DH -15, DH -25, and DH -38. If it is the intention of BRL to seek permanent suspension <br />or not replace or repair the damaged monitoring wells, please provide to the Division a <br />justification as to why the monitoring liability period as it pertains to Rule 4.05.13(3) does <br />not apply. <br />Division's initial comment - According to approved page 2.05 -133i, site TC- 03 -01(B) is completed <br />in the Upper B -Seam and TC -03 -02 is completed in the water bearing unit above the B -Seam and <br />serve as downgradiant monitoring wells. Based on the table accompanying the TR -103 cover <br />letter, both sites TC- 03 -01(B) and TC -03 -02 are currently damaged and could not be <br />rehabilitated. These two sites are required to be monitored for field parameters quarterly and a <br />full suite sample will be conducted semi - annually. In order to meet the requirements of Rule <br />2.05.6(3) and to ensure that the quality of groundwater should not be impacted, stated in the <br />PHC section of the Bowie No. 2 PAP, please provide information addressing which sites will be <br />