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D. A. eerzy - 8 - August 29, 1996 ground water sources as approved by the Division and mineralogical and chemical analyses of aquifer, overburden, and spoil that are adequate to reflect changes in ground water quantity and quality resulting from those activities." BRL agrees that it is required to monitor the upper perched water bearing zone. BRL has nine wells used for monitoring the upper perched water bearing zone. Additionally, HRL monitors all springs potentially associated with the upper perched water bearing zone ("other ground water sources"). These monitoring wells and other points are sufficient, both in number and in location, to effectively monitor the effects, due to mining, of both the quality and quantity of the ground water. Additional monitoring wells are not necessary and will not be proposed at this time. 1t is BRL's determination that none of the perched water bearing zones are an aquifer. Furthermore, Page 2.04-24 states that, as observed by BRL and experienced by others within the region, "The Mesaverde Formation does not contain extensive aquifers. Typically, the formation is dry or the rock units are of such low permeability they yield insufficient water for sustained use." These perched water bearing zones do not exhibit characteristics of "a zone, stratum or group of strata acting as a hydraulic unit that can store and transmit water in sufficient quantities for beneficial use". BRL states, (page 2.04-37) that the perennial streams, springs, and ponds in the permit and adjacent area are of beneficial use to wildlife. There was no indication during the hydrologic investigation that either of the perched water bearing zones feed the surface springs, ponds or perennial streams. Page 2.04-29 states that the near surface colluvial material is the primary source for these springs. This is evidence in part by the quantity fluctuation in the springs' flow and there association with the annual spring anowmelt. However, quality data from springs 1, 7, 14, and 15 might indicate that flow or a portion of their flow is in contact with some other source or stratum. This could indicate potential for water impacts on the surface however, BRL has also agreed to provide alternate sources of water in accordance with Rule 2.05.6(3)(iii), in case the lower perched water bearing zone transmits water to any of the springs on the surface and the mining operation disrupts the surface water flow. x) DtdG - Please propose a downyrariient D-seam monitoring well for baseline and operational monitoring.