2010-07-12_REVISION - C1996083 (2)

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J. J. Dudash -4- July 8, 2010 17. On page 2.04-34 the existing text regarding perched groundwaterhas been modified and the text regarding the Upper Perched Water Zone has been removed. Also it appears that Map 10- Upper Perched Water Zone has been removed from the PAP and replaced with Map 10-A "Above the B-Seam Potentiometric Surface". New text has been added which is confusing and appears to conflict with all of the previous information presented for the Upper Perched Water Zone. Perched groundwater for the Bowie No. 2 mine has always been described as the Lower and Upper Perched Water Zones (located between the Rollins Sandstone member and the "C"coal seam as presented in the revised text and the other located above the "D" coal seam, respectively). What has happened to the discussion of the Upper Perched Water Zone in Section 2.04.7 and is a new perched water zone being described as located above the "B" coal seam (shown on Map 10-A)? Reference to Upper Perched Water Zone still appears throughout the remainder of the text including on pages 2.04-37, 2.05-102, 2.05-115, 2.05-116 (again the Upper Perched water Zone is described in the PHC as above the "D" coal seam), and on page 2.05-130 where Map 10 and the upper perched water zone are referenced again. It appears that BRL is now describing three separate perched water zones. Please clarify the discrepancies identified here regarding the perched water zones and provide clear descriptions and appropriate maps utilizing available information that depicts the potentiometric surface of each. In the June 1, 2010 submittal, BRL revised pages 2.04-34 through 2.04-38. However, it appears that Map 11 is incorrectly referenced on page 2.04-37. Under the last paragraph BRL references Map 11 as showing the upper perched water bearing zone being discontinuous. This appears to be incorrect since Map 11 shows the lower perched water zone not the upper perched water zone. Please check this reference to Map 11 and revise page 2.04-37, if appropriate. BRL - The map reference was changed to Map 10 on page 2.04-37. 18. This issue is resolved. 19. On revised page 2.04-34, reference is made to a HydroGeo June 2008 report in Exhibit 3 of Volume lll. The Division does not have this report. Please inform the Division under which revision this report was incorporated into the permit application. In the submittal dated June 1, 2010, BRL provided the June 2008 report, stating that it was originally submitted in PR-10. However, the June 2008 report deals with the dewatering of the D-seam in preparation for mining the B-seam and, according to Division records, was never submitted in PR-10 for review by the Division. What was submitted in PR-10 and reviewed by the Division was the September 2008 report. When PR-10 was approved, BRL provided a cd which contained copies of the revised material. The June 2008 report was on that cd but the Division did not