2010-07-12_REVISION - C1996083 (2)

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J. J. Dudash -7- July 8, 2010 Section 2.05.6 Mitigation of the Impacts of Mining Operations 42. This issue is resolved. 43.This issue is resolved. 44.This issue is resolved. 45. This issue is resolved. 46.This issue is resolved. 47. This issue is resolved. 48. This issue is resolved. 49. This issue is resolved. 50. This issue is resolved. 51. A major concern in reviewing the proposed western mine plan area with regard to potential groundwater impacts is that none of the monitoring wells associated with the Bowie No. 1 mine plan area have been incorporated into the Hydrologic Monitoring Plan for the new expanded Bowie No. 2 permit area as described on page 2.05-117. The proposed plan includes monitoring wells located at the Terror Creek mains and one proposed well down gradient from a portion of the proposed new disturbance. There are essentially no wells included in the hydrologic monitoring plan that would be either directly up gradient or down gradient from the new disturbance associated with the western mine plan proposal. There appears to be numerous inactive wells from the Bowie No. 1 permit area that would be suitable monitoring wells for the new western mine plan area. In addition, several surface water and groundwater monitoring sites are listed in Tables 1, 3 and 4B in Volume 4 of the Bowie No. 1 Mine permit application along with the footnote that monitoring would be reactivated if mining occurred in the east part of the Bowie No. 1 Mine. Please address this and modify the Hydrologic Monitoring Plan accordingly. 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 13- 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