2010-07-07_REVISION - C1996083 - Laserfiche WebLink

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involved. In order to avoid confusion, it would appear that this revised paragraph should be moved to the discussion on the B-seam coal that begins on revised page 2.04-22. 13. Because the proposed new mining district is quite a distance west of the current Bowie No. 2 Mine area, please incorporate the Bowie No. I Mine acid, toxic and alkalinity forming chemical analyses and discussion in Section 2.04.6 for the B-2 coal seam (designated incorrectly as the D-2 coal seam) and the strata immediately above and below the B-2 coal seam into the Bowie No. 2 Mine permit application in Section 2.04.6(3). In the June 1, 2010 submittal, BRL stated that the requested information was provided on revised page 2.04-26 and in Tab 6 of Volume III. The Tab 6 information was supplied but revised page 2.04-26 was not. Please provide revised page 2.04-26. Section 2.04.7 Hydrology Description 14. Please update the Method of Study history discussion that starts on revised page 2.04-28 of Section 2.04.7 to include the corresponding information found in Section 2.04.7 of the Bowie No. I permit application. This issue is resolved. BRL revised page 2.04-28 in the June 1, 2010 submittal to include the requested discussion. 15. The baseline water monitoring data presented in PR-12 do not correspond with the baseline data currently in the approved permit applications for the Bowie No. I Mine and the Bowie No. 2 Mine. First, the data are presented as summaries, rather than as individual monitoring results. The Division had requested summaries of baseline data for the annual hydrology reports to aid in the adequacy review of the reports. The baseline data in the permit applications should be the original monitoring data. Even as summaries, however, the PR-12 baseline data appear to be summaries of monitoring results from the beginning of monitoring up to 2009, whereas the currently approved baseline data ends at some activation date, as shown in the annual hydrology review data sheets. Since the baseline water monitoring data for the currently approved permit area is already in Exhibit 3 of Volume 111, BRL only needs to transfer the relevant baseline data from the Bowie No. I permit application over to the Bowie No. 2 permit application. BRL submitted revised baseline water monitoring data in the June 1, 2010 submittal. However, the data do not appear to satisfy Rule 2.04.7(2)(a), which require baseline surface water monitoring data to show seasonal variation in quantity and quality. Seasonal variation generally means four consecutive quarters of sampling. The Division has several observations concerning the baseline surface water monitoring data set presented in the June 1, 2010 submittal. In some instances, there is limited seasonal sampling, such as for SW-01, where there is sampling of the same two consecutive quarters in two different years. In other cases, such as for SW-02, sampling is recorded for widely spaced years. In addition, such as for SW-01 and SW10, there are different baseline years from one site to another. Also, several sites, such as SW-05, have operational data presented as baseline data. Please explain BRL's rationale for presenting the baseline surface water monitoring in this fashion or resubmit the baseline data in compliance with Rules 2.04.7(2)(a) and 4.05.13(2). 4