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t <br />To adequately assess changes in the hydrologic balance and to establish baseline <br />information on inflows, mine inflow monitoring and reporting should be incorporated <br />into the approved water quality monitoring program. It is recommended that for flows of <br />sufficient discernable volume (>Sgpm), an initial sample should be obtained for <br />laboratory analyses and then sampled annually thereafter. The parameter list should be <br />the same for the groundwater list currently used. Field parameters (pH, conductivity, and <br />temperature) and inflow rates should be measured quarterly and reported in the AHR. <br />Please submit a proposed plan for mine inflow monitoring including the type and <br />frequency of monitoring to be conducted. Also please update the permit application <br />package to reflect the changes in the water quality monitoring program. <br />12. It appears that monitoring wells DH-I5, DH-39, and DH-49 may be eliminated by <br />mining. DH-IS and DH-49 are important D-Seam monitoring wells and DH-39 is the <br />only overburden monitoring well located in this area. Please provide the Division with a <br />contingency plan for replacement of these wells or any of the other monitoring wells <br />currently included in the hydrology monitoring program if they become inoperable or <br />removed by mining. <br />13. On page Page 2.05 - 105 - (Pazagraph 5), the applicant states; "The subsidence <br />implications dealing with mining in low overburden azeas adjacent to the fault trace will <br />be evaluated when more is known of the chazacteristics of the fault, and before mining <br />will be conducted in that azea." BRL should provide sufficient explanation of the ground <br />control and monitoring methodologies which we be applied during development mining <br />to assure the prevention of detrimental subsidence impacts. The existing permit <br />statements provide no basis for forming an opinion of the plans adequacy. <br />14. The final paragraph on page 2.05 - l06 states: "Pond P-2 is located in a zone of <br />intermediate subsidence, however the overburden below P-2 is nearly 1,000 feet. For all <br />practicable purposes P-2 is in a zone of mine subsidence. Therefore, no limited <br />extraction zone will be provided for Pond P-2." I suspect BRL intended to suggest that P- <br />2 is for all practical purposes in a zone of "minor" mine subsidence. This should be <br />corrected or clazified. Further, BRL should provide a technical justification for believing <br />it appropriate to implement no subsidence control methods beneath Pond P-2. <br />15. On page 2.05 - 107 - (Pazagraph 4), BRL asserts that mining in low overburden azeas <br />adjacent to the fault will be evaluated when more is known about mining in the low <br />overburden areas adjacent to the fault. BRL will have to provide adequate methodology <br />to allow the Division to find that mining can be conducted through the fault without <br />detrimental subsidence impacts. The same is true of Page 2.05 - 110 - (Paragraph 2). <br />16. On pages l7 and l8 of Exhibit 15 in Section 1.8 of Volume III (Subsidence Prediction), <br />3 <br />