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D. A. Berry - 7 - Auquet Z9, 1996 <br />viii) Fie acknowledge that OH-55 should monitor the perched <br />water zone located above the B seam coal. This <br />information is of value, and will be required. <br />Monitoring of t:1re ar;ui.fer below the coal seam to be <br />mined is mandatory. Please explain why additional <br />wells are not proposed for the perched zone below the <br />D-2 seam. Typically, three wells are needed to <br />ascertain impacts, both upgradient and down gradient. <br />Please provide such a plan. <br />BRL agrees that DH-55 will monitor any potential <br />impacts to the lower perched water bearing zone below <br />the proposed seam to be mined. <br />Rule 4.05.13 (1) (b) mandates that, "when surface or <br />underground mining activities may effect ground water <br />systems on or off the permit area, ground water levels <br />and ground water quality shall be periodically <br />monitored." BRL contends that the Bowie No. 2 Mine <br />will have no effect on the lower perched water bearing <br />zone nor has it suggested in section 2.05.6 (b) (iii) <br />that it will. Therefore, BRL does not agree that the <br />monitoring of the lower perched water bearing zone is <br />"mandatory". For this reason additional monitoring <br />wells are not proposed. <br />ix) DMG - BI2L will be required to effectively monitor the <br />upper perched water. bearing zone. Impacts to this zone <br />can translate to water impacts at the surface. The <br />proposed D-seam overburden well should provide valuable <br />upgradient information. Please propose an additional <br />D-seam overburden .yell location at the downyradient: <br />area of the mine. Downgradient D-seam overburden <br />baseline and operati.ona.l data will be required. <br />BRL - BRL has determined that it may effect the upper <br />perched water bearing zone; Paqe 2.05-70 (and others) <br />state that "The underground mining operation may impact <br />the ground water in the Mesaverde Formation. Potential <br />fracturing of the formation and the local increase of <br />permeability above the extracted coal seam could drain <br />all or a portion of a perched water bearing zone." <br />Page 2.05-86 (and others) state that, "disruption of <br />perched water bearing zones will occur due to mining <br />where the water bearing zones lie in the immediate <br />vicinity of the mine roof. Because of the nature of <br />the groundwater, this does not constitute any effect on <br />groundwater resources." If mining activities have the <br />potential to effect the upper perched water bearing <br />zone, Rule 4.05.13 (1) (b) requires that the ground <br />water be monitored and that, "monitoring shall include <br />measurements from a sufficient number of wells or other <br />