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`J <br />Joe Dudash <br />July 28, 2008 <br />Page 2 <br />• BRL has agreed to install additional monitoring wells in their May 12, 2008 PR-10 responses, <br />but these wells would not be installed until 2009. BRL will attempt to install two additional <br />down gradient groundwater monitoring wells (DH-68 B-Seam and one above B-Seam). The <br />proposed wells (DH-68) are located on Iron Point shown on revised Map 9 north of the current <br />permit boundary. This is acceptable to the Division to satisfy the groundwater monitoring <br />requirements of 4.05.13(1) and may also serve as point of compliance well(s). The Division <br />understands that BRL intends to go to the WQCC to get the perched and coal aquifers classified <br />as "Limited Use and Quality". If BRL is successful then additional ground water monitoring <br />(including point of compliance wells) would not be needed for these aquifers. BRL has not <br />proposed a plan for determining the need or location for a point of compliance well in the <br />alluvial aquifer. <br />BRL added language to page 2.05-75ii to fortify the statement that the Rollins Sandstone will <br />not be impacted by the mine workings. Therefore, additional baseline data or additional down <br />gradient monitoring (including point of compliance) would not be required for the Rollins <br />Sandstone. The language proposed by BRL on revised page 2.05-75ii is acceptable, but should <br />be backed up with drill log information and cross-section(s) illustrating that subsurface <br />conditions should prevent integration of water from either the D-Seam or B-Seam into the <br />underlying Rollins Sandstone. The geologic log for drill hole G15 that is referenced in BRL's <br />revised page 2.05-75ii should be incorporated into the PAP and correlated with and updated in <br />appropriate cross-sections. <br />With PR-10 and PR-11, BRL proposes to extend the permit boundary northwards. In <br />accordance with 2.04.6, geologic maps and cross-sections should be updated for the entire <br />permit area. Likewise in accordance with 2.04.7(4) (c), the location and extent of sub-surface <br />water, if encountered, within the proposed permit and adjacent areas should also be updated if <br />available. Please have BRL update Maps 7 and 8 Geology and Geologic Cross-Section and <br />Maps 10 and 11 Upper and Lower Perched Water Zone Mesa Verde Formation, respectively. <br />Please let me know if you have questions. <br />C: Sandy Brown and Denver File