2010-01-08_REVISION - C1996083 ‎(4)‎

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 1/8/2010
• Doc Name: Review Memo
• From: Mike Boulay
• To: Joe Dudash
• Type & Sequence: TR65
• Email Name: JJD
• Media Type: D
• Archive: No

Dudash
January 8, 2010 Page 2
To date, BRL has to the best of their ability provided baseline characterization for groundwater
within each aquifer for the proposed permit and adjacent area. At this point I believe we have
adequate baseline monitoring data for the entire permit area as it exists today. The B-Seam strata
and saturated zones above the B-Seam strata are characterized by several wells across the permit
area including TC-03-02, TC-03-03, DH-58a-inactive, DH-66, and DH-67 Blw. Further, a detailed
water quality analysis using historic monitoring for the B-Seam and strata above the B-Seam was
recently completed by HydroGeo, Inc. for Permit Revision No. 10 and is included in the PAP at
Volume III, Exhibit 3. No additional up gradient monitoring wells for the purpose of baseline
characterization will be necessary for the new disturbance areas. Additional down gradient
monitoring wells will be necessary with the implementation of the plans proposed with TR-65 and
TR-66 as explained below.
With TR-65 there would be no impact to the existing wells P-TC-03-01, P-TC-03-02, and P-TC-
03-03 located to the west and east of Terror Creek. These wells were installed in 2003 and monitor
the following water bearing zones; Well TC-03-01- dual completion in Upper B-Seam and Rollins
sandstone down gradient of the new proposed main entries beneath Terror Creek; Well TC-03-02
and TC-03-03 are both completed above the Upper B-Seam up gradient of the proposed main
entries development and the geotechnical hole/vent shaft installation sites. Collectively these wells
have provided good baseline data for the area proposed for new disturbance at the Terror Creek
main entries and North Mains Rooms.
Currently with the TR-65 proposal there is only one well location P-TC-03-01 down gradient of the
main entries (dual completion in the B-Upper and Rollins sandstone). There is currently no
monitoring above the B-Seam down gradient of the disturbance proposed with TR-65. Prior to
implementation of the TR-65 plan, at a minimum additional down gradient monitoring within the
saturated zone(s) above the B-Seam would be required. Further, with TR-66 the installation of the
ventilation shaft will destroy Well P-TC-03-01. Therefore, eventually there would be no ground
water monitoring at all located beyond the mining disturbance associated with the main entries
beneath Terror Creek. BRL has an approved drill site location P-TC-03-06 approved in 2004 with
TR-28. The wells were never drilled but this location is accessible and would provide an adequate
down gradient monitoring site. At this location wells should be completed within the coal seam to
be mined and the saturated zoneslaquifers above the coal seam.
With regard to the North Mains Rooms additional down gradient monitoring will be required to
assess potential groundwater impacts beyond the mining disturbance area. Currently there are no
ground water monitoring wells in that vicinity. Monitoring wells should be installed within the coal
seam to be mined and the saturated zones/aquifers above the coal seam.
Based on the above discussion, I have the following adequacy comments regarding TR-65.
1. Please provide a plan for incorporating additional ground water monitoring wells at
locations down gradient from the new disturbance/revised mine plan areas proposed with
TR-65. Monitoring wells should be located within the coal seam(s) to be mined and the