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<br />Dudash <br />Page 2 <br />December l6, 1999 <br />I have the following specific comments regarding the 1998 AHR. <br />1. On page 1, Bowie Resources limited (BRL) states that several monitoring points have been <br />removed from the schedule presented in Table I. Monitoring points should not be removed from <br />the approved monitoring plan without an appropriate revision to the permit document and approval <br />from the Division. <br />2. On page 3, BRL indicates that MW-1 is in a location that should be outside the area of <br />influence of the coal stockpile and loadout. However, MW-l shows a significant increase in TDS <br />levels (above the baseline value) for the first and fourth quarter of 1998. Dces BRL know the <br />source of the increase in TDS at this location? Please provide a brief explanation for the significant <br />increase in TDS levels at MW-1. <br />3. On page 5, BRL states that no samples were collected in 1998 from three small area <br />exemption (SAE) sampling points at the east mine fan level. Please provide an explanation for the <br />lack of monitoring data at the SAE locations. <br />4. On Table 1, page 9 BRL indicates that Drill Holes 60, 63, 65, 67, 70, and GR-77-7 have <br />been dropped from surveillance. Any reduction in monitoring frequency must be done through a <br />technical revision to the permit. Quarterly water levels are required for Well Nos. DH-60 and DH- <br />65. DH-60 has a tube used for obtaining water levels and apparently the water level was below the <br />level of the tube during three monitoring attempts in 1998. A water level has not been obtained in <br />DH-65 since the third quarter of 1996 due to an obstruction in the well. BRL states [hat DH-65 has <br />been removed from the sampling program, yet the permit document reflects that both DH-60 and <br />DH-65 aze both still included in the approved monitoring plan. BRL should reconsider the need for <br />monitoring these wells. If appropriate, provide an explanation and rationale for removing them <br />from the sampling plan. A revision to the pemut document will be required for removing them <br />from the approved monitoring plan. <br />5. The surface water monitoring stations listed in Table 1, page 8 of the AHR do not match the <br />stations listed in Volume 4, Table 1 of the permit document. Please clarify this discrepancy. <br />6. The following parameters were not provided for the required groundwater monitoring plan: <br />Water levels for January and February for MW-1, MW-2, and MW-3. <br />Quarterly field parameters and quarterly water quality samples for MW-1 and MW-3. <br />Quarterly water levels for DH-60 and DH-65. <br />The Division notes that field parameters and water analyses were reported for Wells SM-3 and SM- <br />4. These wells are not part of the required sampling plan. <br />7. The Division notes that for the majority of springs, there is no winter monitoring/access. <br />