2008-08-01_REVISION - C1996083 (3)

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BRL initially responded that a revision for new down gradient groundwater monitoring wells would be submitted. However, in a submittal dated July 3, 2007, BRL submitted a May 2007 technical report by R2 Incorporated in support of a request for a variance from the groundwater points of compliance. The Division reviewed the May 2007 technical report and sent adequacy comments to BRL in letter dated August 20, 2007. R2 Incorporated responded directly to the Division with a January 2008 technical report contained in a submittal dated February 14, 2008. The Division sent a preliminary adequacy review letter dated March 20, 2008 for this report. BRL responded in a submittal dated May 12, 2008. Based on discussions between the Division and BRL in the July 10, 2008 meeting and the Division's review of BRL's May 12, 2008 adequacy response to Item 2, the Division has the following comments: A. An important point the Division wants to get across, is that if BRL wants to use existing baseline data rather than gather new baseline data, then BRL must demonstrate with the existing data that the baseline water quality hasn't changed much as you go from south to north within the current permit area, and, then, demonstrate that there is no reason to expect that situation to change as you go even further to the north beyond the current permit boundary (for the mine plans in PR-10 and PR-11). BRL should demonstrate to the Division that the existing wells will satisfy baseline data collection requirements Rules 2.04.7(1) and 2.04.7(4) (c). BRL has indicated the possibility of obtaining baseline information through alternative means such as sampling during development mining. The alternative means for acquiring baseline data is suggested by BRL due to several circumstances including difficult terrain, technical difficulty in drilling extremely deep wells and USFS issues regarding limited access to drill locations. This alternative demonstration if acceptable to the Division should be implemented prior to disturbing beyond the approved disturbance boundary to the north. If BRL cannot demonstrate that the existing well data is adequate for the entire new permit area proposed with PR-10 and PR-11 or cannot provide a suitable alternative means for data collection, then the Division would require additional baseline monitoring wells. B. BRL has agreed to install additional monitoring wells in their May 12, 2008 PR-10 responses, but these wells would not be installed until 2009. BRL will attempt to install two additional down gradient groundwater monitoring wells (DH-68 B-Seam and one above B-Seam). The proposed wells (DH-68) are located on Iron Point shown on revised Map 9 north of the current permit boundary. This is acceptable to the Division to satisfy the groundwater monitoring requirements of 4.05.13(1) and may also serve as point of compliance well(s). The Division understands that BRL intends to go to the WQCC to get the perched and coal aquifers classified as "Limited Use and Quality". If BRL is successful then additional ground water monitoring (including point of compliance wells) would not be needed for these aquifers. BRL has not proposed a plan for determining the need or location for a point of compliance well in the alluvial aquifer. C. BRL added language to page 2.05-75ii to fortify the statement that the Rollins Sandstone will not be impacted by the mine workings. Therefore, additional baseline data or additional down gradient monitoring (including point of compliance) would not be required for the Rollins Sandstone. The language proposed by BRL on revised page 2.05- 2