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This issue is resolved. Culverts C1 through C-4 will continue to be monitored, as shown on revised <br />pages 2.05-119 and 2.05-124 of the June 1, 2010 submittal. <br />49. As shown on the list of water monitoring stations starting on revised page 2.05-120, BRL is proposing <br />to terminate hydrologic monitoring at certain ponds and springs which have decreed water rights or <br />are of high value and that are managed by the USDA-Forest Service. Do any of the federal coal leases <br />require BRL to perform hydrologic monitoring of any of these sites, regardless of whether or not the <br />sites are undermined? <br />This issue is resolved. In their June 1, 2010 submittal, BRL stated that the decreed water rights only <br />need to be monitored if they could potentially be impacted by mining. <br />50. There are several designations for ponds and springs shown on Map 9 which are not on the list of <br />water monitoring sites starting on revised page 2.05-120. The sites located west of Steven's Gulch are <br />ponds 11-8,12-5 and 12-7, spring 1-8 and pond/spring 28, 29 and 1-10. In addition, there are springs <br />5-2 and 6-7 along the West Fork of Terror Creek. Should these sites be removed from Map 9 or were <br />they inadvertently left off of the list of monitoring sites? <br />This issue is resolved. The referenced ponds and springs are meant to be inactive since they are out of the <br />influence of the proposed mining. Map 9 was revised in the June 1, 2010 submittal. <br />51. A major concern in reviewing the proposed western mine plan area with regard to potential groundwater <br />impacts is that none of the monitoring wells associated with the Bowie No. I mine plan area have been <br />incorporated into the Hydrologic Monitoring Plan for the new expanded Bowie No. 2 permit area as <br />described on page 2.05-117. The proposed plan includes monitoring wells located at the Terror Creek <br />mains and one proposed well down gradient from a portion of the proposed new disturbance. There are <br />essentially no wells included in the hydrologic monitoring plan that would be either directly up gradient <br />or down gradient from the new disturbance associated with the western mine plan proposal. There <br />appears to be numerous inactive wells from the Bowie No. I permit area that would be suitable <br />monitoring wells for the new western mine plan area. In addition, several surface water and groundwater <br />monitoring sites are listed in Tables 1, 3 and 4B in Volume 4 of the Bowie No. I Mine permit application <br />along with the footnote that monitoring would be reactivated if mining occurred in the east part of the <br />Bowie No. I Mine. Please address this and modify the Hydrologic Monitoring Plan accordingly. <br />BRL has not provided an adequate response. There are still no wells included in the hydrologic <br />monitoring plan that would be used to assess groundwater impacts associated with the West Mine <br />Expansion. BRL must first provide adequate baseline groundwater data which include the monitoring <br />well identification and completion information and seasonal quantity and quality data. Secondly, BRL <br />shall identify existing wells or if necessary propose new monitoring wells to be included in the hydrologic <br />monitoring plan. The monitoring plan should be designed to assess potential impacts to the hydrologic <br />balance down gradient from the area proposed for new disturbance with the expansion project. These <br />wells shall be incorporated into the approved monitoringplan and the operator shall continue to monitor <br />groundwater quality and quantity throughout the liability period in accordance with the approvedplan. <br />In BRL's response five potential monitoring wells are identified but none are appropriately constructed to <br />monitor the B-Seam or the saturated zone above the B-Seam. Only one of these wells can be located on <br />Map 9 Hydrological Monitoring Location Map. Please revise the application materials and revise the <br />Hydrologic Monitoring Plan to demonstrate compliance with Rules 2.04.7 and 4.05.13. <br />BRL responded in the July 8, 2010 submittal. BRL and the Division are currently working on the <br />resolution of the baseline ground water issue. <br />11