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Jason Musick <br />Page 2 <br />March 11, 2016 <br />With the approval of PR -12, up -gradient (CWI-DH-58 and -60) and down -gradient (2010- <br />1B and -1SS) monitoring wells were incorporated into the PAP and the monitoring plan <br />to monitor the B -Seam and the sandstone above the B -Seam in the western mine plan <br />area. A recommendation was made by the Division to incorporate mine inflow <br />monitoring and sampling to substantiate the observations made at the up -gradient <br />wells. <br />With PR -13, BRL demonstrated the continued separation of the Rollins Sandstone from <br />the area to be mined in the western mine plan area, preventing the need for a down - <br />gradient point of compliance in the Rollins. The Division also approved BRL to mine <br />through 2010-113 and -1SS, in 2015. Furthermore, the Division found that BRL would not <br />be required to replace the down -gradient monitoring wells accepting the reasons <br />(expense and technical difficulty) and the justifications (that down -gradient <br />groundwater is not likely to be put to beneficial use because of: poor ambient water <br />quality, the prohibitive cost of installing a well to sufficient depth, and the difficulty in <br />obtaining USFS approval for the installation of a deep bedrock well; and that the <br />distance to the nearest private landowner (-4 miles) is sufficient to attenuate the <br />effects of BRL's activity on groundwater quality). <br />PR 14 was approved with several stipulations on 10 October 2014. The relevant stipulations to <br />TR99 are as follows: <br />Stipulation No. 42 <br />BRL must rehabilitate or replace groundwater monitoring points CW1-DH-58 and CWI- <br />CH-60 by December 31, 2014. Following the completion of the work, a minor revision <br />must be submitted to update the permit application package text with a discussion of <br />the rehabilitation or replacement of the wells. <br />Stipulation No.43 <br />Within sixty days following the collection of a year of valid baseline data from the down - <br />gradient monitoring wells to be drilled in 2015 (2015-113 and 2015-1SS), BRL must <br />submit a technical revision to update the probable hydrologic consequences section of <br />the permit to establish those wells as groundwater points of compliance, in accordance <br />with rules 2.05.6 (b)(iii) and (iv). <br />At this time the Division has not been provided enough data or sufficient analysis to determine if it is <br />appropriate to approve BRL's revision to not drill additional down -gradient monitoring points for the <br />western mine plan <br />First Adequacy Review Items: <br />1. At a minimum, a full year of down -gradient baseline groundwater data is required in order for <br />the Division to be able to make a future finding as to the impacts of mining on groundwater <br />