2010-07-07_REVISION - C1996083 - Laserfiche WebLink

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BRL has not provided an adequate response. There are still no wells included in the hydrologic monitoring plan that would be used to assess groundwater impacts associated with the West Mine Expansion. BRL must first provide adequate baseline groundwater data which include the monitoring well identification and completion information and seasonal quantity and quality data. Secondly, BRL shall identify existing wells or if necessary propose new monitoring wells to be included in the hydrologic monitoring plan. The monitoring plan should be designed to assess potential impacts to the hydrologic balance down gradient from the area proposed for new disturbance with the expansion project. These wells shall be incorporated into the approved monitoring plan and the operator shall continue to monitor groundwater quality and quantity throughout the liability period in accordance with the approved plan. In BRL's response five potential monitoring wells are identified but none are appropriately constructed to monitor the B-Seam or the saturated zone above the B-Seam. Only one of these wells can be located on Map 9 Hydrological Monitoring Location Map. Please revise the application materials and revise the Hydrologic Monitoring Plan to demonstrate compliance with Rules 2.04.7 and 4.05.13. 52. The information on revised page 2.05-120 and on Map 9 shows that there is no upstream monitoring site for Steven's Gulch. An upstream monitoring site is needed to compare with the monitoring information gathered at downstream monitoring site SW-5. Please propose a Steven's Gulch upstream monitoring site or explain why such a site is impractical. In their June 1, 2010 submittal, BRL stated that it was impractical to establish an upstream monitoring station on Steven's Gulch creek since the creek begins just south of the permit boundary. However, referring to revised Map 9, there appears to be a stretch of Steven's Gulch Creek that is upgradient of the proposed mining. The Division requests that BRL consider the practicality of establishing an upstream station in this upgradient section of the creek. 53. A discussion of the Bruce Park Dam begins on page 2.05-136 The permit text continues to refer to the Bruce Park Dam, while the various permit maps use the name "Terror Creek Reservoir". In the interest of clarity, please consider adding, "and Bruce Park Dam " to the feature on the various maps and/or modify the permit text to explain that the reservoir formed by the Dam is the Terror Creek Reservoir. This issue is resolved. BRl revised page 2.05-136 in the June 1, 2010 submittal. 54. Please explain why the creek in Steven's Gulch is not included along with Hubbard Creek and Terror Creek in the discussions on revised pages 2.05-136 and 2.05-142. Pages 2.05-136 and 2.05-142 were revised in the June 1, 2010 submittal. However, it is stated on revised page 2.05-136 that the creek in Steven's gulch is a perennial stream. On page 49 of Section 2.04 of the Bowie No. 1 Mine permit application, it is stated that Steven's Gulch is an ephemeral stream. Please reconcile this difference. 55. Discussion of the Bruce Park landslide begins at the top of page 2.05-137. While the feature is analyzed in detail in the referenced Yeh study, the location of the landslide is not apparent on Map 06 - Geological Hazards. Please modem Map 06 to indicate the location of the Bruce Park landslide feature. This issue is resolved. Map 06 was revised in the June 1, 2010 submittal. 56. The third paragraph on page 2.05-137 describes the Hubbard Creek road. Please update the text to incorporate the new Hubbard Creek Fansite. 11