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Christine Johnston <br />Mountain Coal Company <br />Page 3 <br />November 12, 1997 <br />Replacement of damaged wells must occur to ensure compliance with the required <br />groundwater monitoring plan for the West Elk Mine. These problems indicate <br />noncompliance with the required groundwater monitoring plan, and a notice of violation <br />will be issued. <br />9. Please clarify the sixth sentence of the third paragraph on page 38. The Division is <br />unclear as to what is meant by this sentence. <br />10. On page 41 under B-Seam Wells, MCC states that well C-72-H was lost due to mining in <br />WY 1994. Yet data are presented for 1995 and 1996 for this well. Please explain how <br />data were collected or if this well has been replaced. <br />11. [n conjunction with comment #8 above, the Division recommends the replacement of <br />well SOM-23-H-1, so that groundwater conditions within the B-Seam can be accurately <br />monitored at this location. Refer to MCC's discussion of well SOM-23-H-1 on page 42 <br />of the AHR. If appropriate, the Division also recommends the replacement of well LP-1, <br />so that groundwater conditions within the Rollins Sandstone can be adequately monitored <br />at this location. On page 43 of the 1996 AHR, MCC states that water level observations <br />in well LP-1 have been non-existent since its inception as a monitoring well in 1994. The <br />1995 AHR reports a depth to water level at 118.86 feet for the third sampling period. <br />Well completion data indicate that the total depth of the well is 260.0 feet. This indicates <br />that there is plenty of well volume to collect a sample, and water levels are existent since <br />its inception as a monitoring well in 1994. Inconsistency between the 1995 AHR and <br />1996 AHR for LP-1 data indicates a problem with data reliability. [f wells SOM-23-H-1 <br />and LP-1 aze damaged, then well replacement must occur to effect compliance with the <br />required monitoring plan. A notice of violation will be issued due to the problems noted <br />above. <br />12. Please clarify the first sentence under Groundwater on page 44. According to page 37 <br />of the AHR, there aze 32 wells in the groundwater monitoring program and fifteen wells <br />were monitored in WY96. <br />13. Please provide a definition and footnote for the less than sign (<) that appears on the <br />Surface Water Quality Tables (Appendix C), the Springs Water Quality Tables <br />.(Appendix F), and the Wells Water Quality Tables (Appendix 1). Each table should be <br />footnoted. <br />14. The following required analytical data were not provided in Appendix C- Surface Water <br />Quality Tables: <br />