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J. J. Dudash -5- June 1, 2010 <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 potentiometric surface of each. <br />BRL - Pages 2.04-34 through 38 were revised. Discussion of the perched water bearing zones <br />was expanded. <br />18. On page 2.04-34 coal seam groundwater is described under Mesaverde Formation - <br />Perched Groundwater. New discussion has been added regarding the potentiometric <br />surface map of the D-Seam and new Map 10-13 presenting the potentiometric surface of the <br />B-Seam has also been added. It would be helpful and easier to follow if the discussion of <br />the coal-seam groundwater was broken out into a new separate paragraph, and rather than <br />reference the D-Seam potentiometric surface from HydroGeo's June 2008 report add a new <br />Map 10-C for the D-Seam potentiometric surface. It also appears that the last paragraph on <br />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 <br />these suggested changes to the permit text. <br />BRL- The last paragraph on page 2.04-39 was deleted except for the comment regarding <br />groundwater in the coal seams which was moved to page 2.04-34. The D-Seam potentiometric <br />surface is now shown on Map 10B. <br />19. On revised page 2.04-34, reference is made to a HydroGeo June 2008 report in Exhibit 3 of <br />Volume III. The Division does not have this report. Please inform the Division under which <br />revision this report was incorporated into the permit application. <br />BRL - The report should have bee included with PR-10. Enclosed is a copy of the report. <br />20. On pages 2.04-36 and 2.04-37 reference to Map 10 has been removed and replaced with <br />Maps 10A and 106. 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 />BRL - Pages 2.04-34 through 38 were revised. Discussion of the upper perched water bearing <br />zone was expanded. <br />21. 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 />BRL - The revised text states the geohydrologic setting changes west of Terror Creek. <br />Additionally, the northeastern lower perched water bearing zone is located north and down dip of <br />the western mining area. If lower perched water bearing zone contours were projected to the <br />west, most contours would be located north of the western mining area.