Laserfiche WebLink
J. J. Dudash -3- July 8, 2010 <br />Section 2.04.7 Hydrology Description <br />14. This issue is resolved. <br />15. The baseline water monitoring data presented in PR-12 do not correspond with the <br />baseline data currently in the approved permit applications for the Bowie No. 1 Mine <br />and the Bowie No. 2 Mine. First, the data are presented as summaries, rather than <br />as individual monitoring results. The Division had requested summaries of baseline <br />data for the annual hydrology reports to aid in the adequacy review of the reports. <br />The baseline data in the permit applications should be the original monitoring data. <br />Even as summaries, however, the PR-12 baseline data appear to be summaries of <br />monitoring results from the beginning of monitoring up to 2009, whereas the <br />currently approved baseline data ends at some activation date, as shown in the <br />annual hydrology review data sheets. Since the baseline water monitoring data for <br />the currently approved permit area is already in Exhibit 3 of Volume lll, BRL only <br />needs to transfer the relevant baseline data from the Bowie No. 1 permit application <br />over to the Bowie No. 2 permit application. <br />BRL submitted revised baseline water monitoring data in the June 1, 2010 submittal. <br />However, the data do not appear to satisfy Rule 2.04.7(2)(a), which require baseline <br />surface water monitoring data to show seasonal variation in quantity and quality. <br />Seasonal variation generally means four consecutive quarters of sampling. The <br />Division has several observations concerning the baseline surface water monitoring <br />data set presented in the June 1, 2010 submittal. <br />In some instances, there is limited seasonal sampling, such as for SW-01, where <br />there is sampling of the same two consecutive quarters in two different years. In other <br />cases, such as for SW-02, sampling is recorded for widely spaced years. In addition, <br />such as for SW-01 and SW10, there are different baseline years from one site to <br />another. Also, several sites, such as SW-05, have operational data presented as <br />baseline data. <br />Please explain BRL's rationale for presenting the baseline surface water monitoring in <br />this fashion or resubmit the baseline data in compliance with Rules 2.04.7(2)(a) and <br />4.05.13(2). <br />BRL- The baseline data presented is the most current information that includes <br />laboratory data. A case could be made that spring and fall monitoring is "seasonal" <br />and that would bring most of the monitoring sites into compliance with rule 2.04.7. <br />BRL has reactivated monitoring all of Bow-1 the baseline monitoring points. Bowie <br />should have data for the 1 st and 2nd quarter of 2010 in the next month so the tables <br />can be updated. The operational data was removed from eleven of the monitoring <br />points. Enclosed are the eleven amended baseline monitoring sheets. <br />16. This issue is resolved.