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Mining activities during 2021 include continued expansion of the L and N <br /> pits and <br /> the initial removal of coal in the I Pit West <br /> The I Pit West is not shown on the currently approved version of Map M4,Life of <br /> Mine Plan(dated 3/30/22). It is the Division's understanding that the I Pit West is <br /> being proposed with this revision(i.e. PR-11). <br /> Please clarify whether mining of the I Pit West has already begun,or whether this is a <br /> typo in the 2021 AHR. <br /> 53. Proposed Section 4.8.5.2 (page 4-242) describes the groundwater monitoring plan. <br /> The text states that: <br /> In Technical Revision TR-93, the Division and Trapper Mining Inc. agreed <br /> that well GP-9 is the point of compliance for the Basic Standard for Ground <br /> Water for the Third White sandstone. In Technical Revision TR-96, the <br /> Division and Trapper Mining Inc. agreed that the Coy well is the point of <br /> compliance for the Basic Standards for Ground Water for the Flume Gulch <br /> alluvium. <br /> Clearly GP-9 is not appropriately located to act as a point of compliance for the <br /> disturbance proposed with PR-11. <br /> Please propose additional points of compliance for all aquifers that have the potential <br /> to be impacted by the disturbance proposed with PR-11,including alluvial aquifers. <br /> 54. The applicable standard at the points of compliance is the Interim Narrative Standard <br /> from Regulation 41, The Basic Standards for Groundwater(Reg 41). The Division <br /> does not have the authority to set standards, but it does have the authority to use <br /> historic monitoring data to determine numerical values for groundwater quality <br /> parameters, if suitable data is available. If no data is available then the most stringent <br /> values from Tables 1 —4 of Reg 41. (Further details of the Division's interpretation <br /> of Reg 41 is given in a Groundwater Monitoring and Protection Technical Bulletin <br /> published in 2019, and available via the Division's website, or directly from the <br /> reference given below). <br /> Please consider formalising how the Interim Narrative Standard will be applied at the <br /> groundwater points of compliance either with PR-11,or with a Technical Revision <br /> following the approval of PR-11. <br /> References <br /> 21 <br /> Trapper Mine PR11 ADQ No 2 <br /> 2023 February <br />