2008-06-12_REVISION - C1996083 - Laserfiche WebLink

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points of compliance. The Division reviewed the May 2007 technical report and sent adequacy comments to BRL in letter dated August 20, 2007. Rz 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. The Division understands that BRL will appear before the Water Quality Control Division to have the perched aquifers and coal aquifer classified as "Limited Use and Quality." The Division has also requested that BRL demonstrate to the Division that there is no potential to negatively impact the quality of ground water or the hydrologic regime in the Rollins sandstone. If these actions are successful, then BRL would not need to construct ground water wells down gradient of the B-seam mining in order to obtain baseline data or to establish ground water points of compliance. 3. Because future mining will be extending northward past the current upgradient stream monitoring locations on Hubbard Creek and Terror Creek, please propose new upgradient stream monitoring locations for these two streams. The new locations should be upgradient of all proposed mining. For these new upgradient water monitoring locations, baseline water monitoring, similar to that performed for the current stream stations, will be needed, per Rule 2.04.7. Also, please revise the permit text and maps where appropriate. BRL responded that surface water monitoring stations D34-14 and D32-4 are up gradient of the proposed mine workings,. In an e-mail dated February 22, 2007, the Division requested that flow measurements be made during the winter and early spring months of 2007 at these two sites to complete baseline monitoring. In the submittal dated January 30, 2008, BRL stated that they asked the USGS to monitor flow at the two stations in the winter. March 2007 data has been recorded and is listed in the January 30, 2008 cover letter but BRL has not received the fall 2007 data yet. Please provide the remaining baseline flow data when it is received. 4. Rule 2.04.7(3) requires alternate water supply information if contamination, diminution or interruption of a surface water source may result from the effects of mining. Since mining effects could damage the main and saddle dams of the Terror Creek Reservoir, as stated in Section 2.05.6(6)(b)(i)(C) of the revised permit text, please revise this section of the permit text to include an appropriate discussion concerning the Terror Creek Reservoir. BRL initially responded in the December 28, 2006 cover letter that, based on their subsidence and seismicity studies, they were revising the statement of the worst possible consequences in Section 2.05.6(6)(b)(i)(C) to state that the Bruce Park (Terror Creek) Reservoir and dam should not be affected by mining operations and, therefore, alternate water supply information under Rule 2.04.7(3) was not needed. Four permit text items were revised in the January 30, 2008 submittal from BRL to show that the operator had prepared a seismic and subsidence monitoring program per Rule 2.05.6(6)(c). However, based on information from the Division of Water Resources, the Division is concerned about the possibility that mine induced seismicity could cause the Bruce Park landslide to slide into the Terror Creek Reservoir, thereby decreasing the storage volume of the reservoir and possibly causing stored reservoir water to flow over the Bruce Park Dam embankment. Therefore, 2