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TR -20 alone is a "significant alteration in the operator's reclamation plan. <br />TR -24 is far more than an incidental adjustment to the boundary; it seems it is almost 90 <br />acres, and apparently includes BLM coal not previously under permit. Whether it <br />includes BLM coal not yet under lease, I leave to you and the BLM to sort out. TR 24 <br />would add something like 87.3 acres to the permit area. <br />TR — 23 is an expansion of production of over 50%. <br />TRs 24 and 25 address surface and groundwater, two of the biggest public concerns <br />about this project. <br />There is also no justification for treating these matters as Technical Revisions, whether <br />considered separately or together. Therefore, we believe that the Division should <br />reconsider its determination and decide that this submittal by GCC (including TRs 20, 23, <br />24, 25 and 26) is more properly reviewed as a Permit Revision. <br />As to the ground and surface water monitoring: <br />• Well clusters should be redesigned to include wells which penetrate below the <br />existing potentiometric surface in order to establish baseline geohydrology and <br />groundwater chemical conditions. <br />• At least some of the wells should be drilled deep enough that they intercept <br />groundwater. <br />• The proposed monitoring parameters should be expanded to better inform <br />baseline groundwater chemistry. These may be inadequate for establishing an <br />adequate water quality baseline of conditions as they exist prior to the <br />expansion of mining into new coal leases. <br />• At least one new alluvial well and surface water monitoring point should be <br />established in Hay Gulch to the south of the current "downgradient" monitoring <br />location. This new monitoring point should be designed to detect possible <br />changes in the hydrology and water chemistry at a point below Schoolhouse <br />Canyon. <br />It would be prudent to establish upgradient and downgradient alluvial <br />groundwater and surface water monitoring stations in East Alkali <br />Gulch. Although the new MW clusters 3 and 4 will be completed to the east of <br />East Alkali Gulch, these wells are not designed to intercept alluvial groundwater. <br />• Core samples from the A seam, overburden, and inter -burden between the A <br />and B seams should be collected and tested for potentially acid generating <br />