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Dudash <br />Page 3 <br />May 14, 2010 <br />5. It is unclear why the lower perched water bearing zone was not projected into the new <br />mining area as described on revised page 2.04 -36. Since the available information indicates <br />that the lower perched water bearing zone lies above the B -Seam and could be impacted by <br />B -Seam Mining in the new western mine plan area, it should be projected into the new area. <br />Please clarify this and revise the permit text accordingly. <br />6. A major concern in reviewing the proposed western mine plan area with regard to potential <br />groundwater impacts is that none of the monitoring wells associated with the Bowie No. I <br />mine plan area have been incorporated into the Hydrologic Monitoring Plan for the new <br />expanded Bowie No. 2 permit area as described on page 2.05 -117. The proposed plan <br />includes monitoring wells located at the Terror Creek mains and one proposed well down <br />gradient from a portion of the proposed new disturbance. There are essentially no wells <br />included in the hydrologic monitoring plan that would be either directly up gradient or <br />down gradient from the new disturbance associated with the western mine plan proposal. <br />There appears to be numerous inactive wells from the Bowie No. 1 permit area that would <br />be suitable monitoring wells for the new western mine plan area. Please address this and <br />modify the Hydrologic Monitoring Plan accordingly. <br />7. The Active Monitoring Wells Completion Summary Table that is currently provided in the <br />PAP on page 2.05 -83 appears to have been removed from the permit text. This table <br />contains critical information that needs to be retained in the permit document. Please <br />ensure that this table is updated for the revised groundwater monitoring plan if needed and <br />reincorporated into the PAP. <br />If you have questions or need additional information, please let me know. <br />C: Denver File <br />