2008-08-29_APPLICATION CORRESPONDENCE - C2008086

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Gary Isaac CAM-Colorado, LLC August 29, 2008 Page 10 presented for the bedrock groundwater monitoring well 8-2-8. With well 8-2-8 the DEIS presents the following statement "the bedrock that overlies the Cameo coal zone at this location contains minimal, if any, groundwater and the Cameo coal zone yields very little water". In the PAP, CAM states that "the bedrock beneath the Cameo coal zone at this location contains minimal, if any, groundwater and the Cameo coal zone yields very little water". The information presented in the PAP regarding water levels in well 8-2-8 is still inconsistent and not clearly stated. In the first sentence of the second paragraph of page 2.04-20 CAM indicates that water levels were measured "below the coal seam" at depths ranging from 391 to 394 feet below ground surface (bgs). The second sentence indicates that "water levels are near the bottom few feet of the Cameo coal zone." Finally in the third sentence CAM indicates that "the Cameo coal zone yields very little water." Based on our review of the well completion information presented in the PAP, it appears that well 8-2-8 was intended to monitor the sandstone below the Cameo coal seam. The well is screened at an interval below the Cameo coal horizon from 384 to 394 feet bgs. The Cameo coal zone is higher at 357 to 375 feet bgs at this location. Thus, well 8-2-8 is not a good indicator of water yield from the Cameo coal seam. Water levels are not near the bottom few feet of the Cameo coal zone, but within the screened interval of the well more than fifteen feet below the bottom of the coal seam. Please clarify the discussion on page 2.04-20 regarding the occurrence of groundwater as measured at well 8-2-8 and clearly state which zone/formation it is intended to monitor. 29. Well 8-3-10 is a better indicator of the occurrence of groundwater because it is screened across the Cameo coal zone. The well was installed with a "cellar" of blank casing below the well screen and water levels remained consistently at a level approximately 26 feet below the bottom of the coal seam. Recently the well has been dry. This is a good indication that the Cameo coal zone does not produce significant water at this location. There is an inconsistency noted with the screened interval information presented in the PAP. This well was intended to monitor within the seam to be mined. Page 2.04-20 shows the screened interval equivalent to the Cameo coal zone interval at 492 to 510 feet bgs. However, the well completion log presented in Volume III Tab 3H shows the groundwater monitoring zone above the Cameo coal horizon. Please clarify this discrepancy on the well completion log and clearly indicate in the PAP which zone/formation the well 8-3-10 is intended to monitor. 30. The information presented for bedrock groundwater quantity and quality is not sufficient to establish adequate baseline information for the permit and adjacent areas. The information presented under 2.04.7 Hydrology Description and 2.05.6(3) Protection of hydrological balance minimally addresses the requirements of Rules 2 and 4. This was deemed sufficient for the purposes of filing a complete application. However, the data presented for bedrock groundwater is not adequate in terms of meeting the requirements of baseline groundwater characterization and development of an on ongoing groundwater monitoring plan. The data and discussions presented in the PAP are based solely on one