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monitoring wells. <br />17. On page 2.04-34 the existing text regarding perched groundwater has been modified and the text <br />regarding the Upper Perched Water Zone has been removed. Also it appears that Map 10 - Upper <br />Perched Water Zone has been removed from the PAP and replaced with Map 10-A "Above the B-Seam <br />Potentiometric Surface". New text has been added which is confusing and appears to conflict with all of <br />the previous information presented for the Upper Perched Water Zone. Perched groundwater for the <br />Bowie No. 2 mine has always been described as the Lower and Upper Perched Water Zones (located <br />between the Rollins Sandstone member and the "C" coal seam as presented in the revised text and the <br />other located above the "D" coal seam, respectively). What has happened to the discussion of the Upper <br />Perched Water Zone in Section 2.04.7 and is a new perched water zone being described as located above <br />the "B" coal seam (shown on Map 10-A)? Reference to Upper Perched Water Zone still appears <br />throughout the remainder of the text including on pages 2.04-37, 2.05-102, 2.05-115, 2.05-116 (again the <br />Upper Perched water Zone is described in the PHC as above the "D" coal seam), and on page 2.05-130 <br />where Map 10 and the upper perched water zone are referenced again. It appears that BRL is now <br />describing three separate perched water zones. Please clarify the discrepancies identified here regarding <br />the perched water zones and provide clear descriptions and appropriate maps utilizing available <br />information that depicts the pontetiometric surface of each ? <br />18. On page 2.04-34 coal seam groundwater is described under Mesaverde Formation - Perched <br />Groundwater. New discussion has been added regarding the potentiometric surface map of the D-Seam <br />and new Map 10-B presenting the potentiometric surface of the B-Seam has also been added. It would <br />be helpful and easier to follow if the discussion of the coal-seam groundwater was broken out into a new <br />separate paragraph, and rather than reference the D-Seam potentiometric surface from HydroGeo's June <br />2008 report add a new Map 10-C for the D-Seam potentiometric surface. It also appears that the last <br />paragraph on page 2.04-39 regarding the occurrence of groundwater in the coal seam should be added to <br />this discussion and moved up to page 2.04-34/35. If deemed appropriate, please make these suggested <br />changes to the permit text. <br />19. On revised page 2.04-34, reference is made to a HydroGeo June 2008 report in Exhibit 3 of Volume <br />III. The Division does not have this report. Please inform the Division under which revision this report <br />was incorporated into the permit application. <br />20. On pages 2.04-36 and 2.04-37 reference to Map 10 has been removed and replaced with Maps 1 0A and <br />10B. The upper perched water zone is described on Page 2.04-37 but it is unclear which map now shows <br />the Upper Perched Water Zone, if any. Under the heading Upper Perched Water Zone and Rollins <br />Sandstone please describe the upper perched zone and what map now depicts the potentiometric surface <br />of this water bearing zone. <br />21. It is unclear why the lower perched water bearing zone was not projected into the new mining area as <br />described on revised page 2.04-36. Since the available information indicates that the lower perched <br />water bearing zone lies above the B-Seam and could be impacted by B-Seam Mining in the new western <br />mine plan area, it should be projected into the new area. Please clarify this and revise the permit text <br />accordingly. <br />22. On revised page 2.04-46, there is a discussion of the gain-loss report on Terror Creek. Please add to <br />the discussion how the results of this report may have been impacted by current mining or may impact <br />future mining plans in the immediate area. Please include in the discussion references to the permit <br />4