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Dudash <br />Page 2 <br />May 14, 2010 <br />1. On revised page 2.04 -32 BRL describes one down gradient monitoring well for the western <br />mining district located in the Terror Creek drainage (TC- 03 -03) and that they propose to <br />install an additional down gradient monitoring well (2010 -1) during 2010. Existing well <br />TC -03 -03 monitors the sandstone above the B -Upper Seam. BRL has not identified what <br />the completion zone will be for the 2010 -1 well. Please add to page 2.04 -32 a brief <br />discussion of what zones will be monitored with each of these monitoring wells. <br />2. On page 2.04 -34 the existing text regarding perched groundwater has been modified and the <br />text regarding the Upper Perched Water Zone has been removed. Also it appears that Map <br />10 — Upper Perched Water Zone has been removed from the PAP and replaced with Map <br />10 -A "Above the B -Seam Potentiometric Surface ". New text has been added which is <br />confusing and appears to conflict with all of the previous information presented for the <br />Upper Perched Water Zone. Perched groundwater for the Bowie No. 2 mine has always <br />been described as the Lower and Upper Perched Water Zones (located between the Rollins <br />Sandstone member and the "C" coal seam as presented in the revised text and the other <br />located above the "D" coal seam, respectively). What has happened to the discussion of the <br />Upper Perched Water Zone in Section 2.04.7 and is a new perched water zone being <br />described as located above the "B" coal seam (shown on Map 10 -A)? Reference to Upper <br />Perched Water Zone still appears throughout the remainder of the text including on pages <br />2.04 -37, 2.05 -102, 2.05 -115, 2.05 -116 (again the Upper Perched water Zone is described in <br />the PHC as above the "D" coal seam), and on page 2.05 -130 where Map 10 and the upper <br />perched water zone are referenced again. It appears that BRL is now describing three <br />separate perched water zones. Please clarify the discrepancies identified here regarding the <br />perched water zones and provide clear descriptions and appropriate maps utilizing available <br />information that depicts the pontetiometric surface of each. <br />3. 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 <br />the D -Seam and new Map 10 -B presenting the potentiometric surface of the B -Seam has <br />also been added. It would be helpful and easier to follow if the discussion of the coal -seam <br />groundwater was broken out into a new separate paragraph, and rather than reference the D- <br />Seam potentiometric surface from HydroGeo's June 2008 report add a new Map 10 -C for <br />the D -Scam potentiometric surface. It also appears that the last paragraph on page 2.04 -39 <br />regarding the occurrence of groundwater in the coal seam should be added to this discussion <br />and moved up to page 2.04- 34135. If deemed appropriate, please make these suggested <br />changes to the permit text. <br />4. On pages 2.04 -36 and 2.04 -37 reference to Map 10 has been removed and replaced with <br />Maps i OA and 1OB. The upper perched water zone is described on Page 2.04 -37 but it is <br />unclear which map now shows the Upper Perched Water Zone, if any. Under the heading <br />Upper Perched Water Zone and Rollins Sandstone please describe the upper perched zone <br />and what map now depicts the potentiometric surface of this water bearing zone. <br />