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Jason Musick <br />Page 3 <br />March 11, 2016 <br />quantity and quality. If BRL intends to mine through 2010-113 and -1SS with less than a year of <br />valid baseline data collected then it will be necessary to drill new wells for baseline data <br />collection, such as 2015-16 and -ISS. <br />A year of down gradient baseline groundwater data has been provided to the Division as <br />requested. This item is adequately addressed. <br />2. Please propose either: a plan to install down -gradient groundwater points of compliance and/or <br />monitoring points; or a detailed analysis demonstrating why such points are unnecessary, with <br />reference to the performance standard criteria laid out in rules 4.05.11 and 4.05.13. <br />No additional discussion or analysis has been provided by operator. The referenced <br />section of the PAP beginning on page 2.04-36 appears to be unchanged from the original TR -99 <br />application submission. <br />Second Adequacy Review Items <br />3. Wells DH -15, DH -25, and DH -38 have been reported as damaged in the (02/16) revised pages. <br />The Operator "commits to installing a new D -Seam monitoring well in the general location of <br />DH -15 by July 31, 2016." With the mine currently not operating is this still the intent of the <br />operator? Additionally, these changes have not been reflected in an updated Map 09 <br />Hydrological Monitoring Location Map. <br />4. The proposed revised text currently states that monitoring wells 2010-1SS and 2010-18 will be <br />mined through during late 2016 and that these wells will not be replaced by down gradient <br />points of compliance. Due to the mine currently being non -operational this text revision does not <br />to represent an accurate timetable. These wells (2010-1SS and 2010-18) should continue to be <br />monitored as the down -gradient wells within the groundwater monitoring plan. <br />