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Mr. Darcy Ferguson -8- February 18, 1993 <br />3. Monitoring wells should all be located outside the planned <br />pit disturbance and should monitor those water-bearing zones <br />which will potentially be impacted by mining. In addition, <br />each water-bearing zone should be monitored by multiple <br />wells, preferably at least three, to provide reproducible <br />information. Lastly, it is the hydrologist's understanding <br />that coal is to be acquired from the Shamrock, Carbonara and <br />Lewis coal seams. Please confirm or otherwise address this. <br />a. Please revise page 4-10, as it indicates that the <br />water-bearing zone above the Shamrock coal rider is <br />inappropriate for monitoring as it is outside the <br />planned pit disturbance. <br />b. Propose a monitoring plan that includes multiple wells <br />in each identified water-bearing formation (aquifer). <br />Consider the use of the wells for which there are well <br />permits, if the perforated interval is well <br />characterized. <br />c. Carbon Junction would be well advised to acquire some <br />baseline information on the Hoverman Well. Table 4-4 <br />indicates there some confusion about the depth and <br />water level in that well. <br />4. It is most unusual to find a site where there has only been <br />one set of full suite analyses performed of the water <br />quality. Please review the aforementioned Guidelines and <br />revise the monitoring plan to include full suite analyses on <br />all samples for the first three years. As limited as the <br />geochemistry information is, results did suggest that there <br />may be water quality concerns with zinc, lead and <br />molybdenum. <br />5. Propose a spoils monitoring program to commence following <br />reclamation and through the bond liability period. Include <br />proposed well locations in both the fill and the backfilled <br />pit, as well as an annual spring and seep survey. <br />6. Notations on the driller's log (Appendix 4.3) for well B-17 <br />are inconsistent. Is the hole cased to 20' or 80'? Is 6" <br />I.D. PVC used or 5" PVC? Is the hole open below the casing <br />or was it sealed below 80'? In addition, were any packers <br />installed to limit inflow into the well from above 20' and <br />below 60'? <br />