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for the permit and adjacent area. There is a general lack of data to satisfy the minimum baseline data <br />requirements and given the proposed plan there would be disturbance beyond the limit of the current <br />down gradient monitoring locations. The Division requires that BRL provide better characterization <br />of the upper and lower perched aquifers that are described in the permit. As discussed below under <br />Item 2C, the question regarding the Rollins Sandstone has been successfully resolved. <br />Additional down gradient monitoring wells should be required for the perched water zones and the B <br />coal seam at or beyond the limit of proposed disturbance associated with PR-10 (and will also be <br />necessary for the PR-11 extension). Ideally these wells should be installed and monitored ahead of <br />time so that the seasonal baseline characterization of the perched water zones at the northern end ofthe <br />permit boundary can be established before they are potentially disturbed. The perched water zones are <br />described by BRL as (above the D-Seam), and (below the D-Seam and above the B-Seam). The <br />Upper and Lower Perched Water Zones should be shown in cross-section and BRL should provide the <br />Division with a plan for the Division's approval to install additional monitoring wells that will <br />adequately characterize and provide monitoring for these zones and the B-Seam coal at or beyond the <br />limit of disturbance proposed with PR-10 (and will also be necessary for the PR-11 extension). <br />2B. No response required. Please note that BRL has not proposed a plan for determining the need or <br />location for a point of compliance well in the alluvial aquifer. <br />2C. Response accepted. BRL updated the Geologic Cross-Section as requested and has demonstrated that <br />the Rollins Sandstone should not be impacted by the mining operation. <br />2D. Response accepted. <br />If you have any questions, please call me. <br />Sincerely, <br />4:seipJ. dash <br />ironmental Protection Specialist <br />cc: Jim Stover P.E. (J.E. Stover & Associates) <br />Ryan Taylor (USDA-Forest Service) <br />Desty Dyer (Bureau of Land Management) <br />Jason Ward (Colorado Division of Water Resources-Montrose) <br />R. Olen Lund (Board of Delta County Commissioners) <br />John Mathewson (Terror Ditch and Reservoir Company) <br />Steve Wolcott and Peggy Herzog (WSERC) <br />c:\word\bowie2\pr l Oadeg7 <br />2