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This issue is resolved. The submittal dated July 8, 2010 contained revised pages 2.04-21 and 2.04-22. <br />13. Because the proposed new mining district is quite a distance west of the current Bowie No. 2 Mine <br />area, please incorporate the Bowie No. 1 Mine acid, toxic and alkalinity forming chemical analyses <br />and discussion in Section 2.04.6 for the B-2 coal seam (designated incorrectly as the D-2 coal seam) <br />and the strata immediately above and below the B-2 coal seam into the Bowie No. 2 Mine permit <br />application in Section 2.04.6(3). <br />This issue is resolved. Tab 6 of Volume III information was provided in the June 1, 2010 submittal <br />and revised page 2.04-26 was provided in the July 8, 2010 submittal. <br />Section 2.04.7 Hydrology Description <br />14. Please update the Method of Study history discussion that starts on revised page 2.04-28 of Section <br />2.04.7 to include the corresponding information found in Section 2.04.7 of the Bowie No. I permit <br />application. <br />This issue is resolved. BRL revised page 2.04-28 in the June 1, 2010 submittal to include the requested <br />discussion. <br />15. The baseline water monitoring data presented in PR-12 do not correspond with the baseline data <br />currently in the approved permit applications for the Bowie No. I Mine and the Bowie No. 2 Mine. <br />First, the data are presented as summaries, rather than as individual monitoring results. The Division <br />had requested summaries of baseline data for the annual hydrology reports to aid in the adequacy <br />review of the reports. The baseline data in the permit applications should be the original monitoring <br />data. Even as summaries, however, the PR-12 baseline data appear to be summaries of monitoring <br />results from the beginning of monitoring up to 2009, whereas the currently approved baseline data <br />ends at some activation date, as shown in the annual hydrology review data sheets. Since the baseline <br />water monitoring data for the currently approved permit area is already in Exhibit 3 of Volume III, <br />BRL only needs to transfer the relevant baseline data from the Bowie No. I permit application over to <br />the Bowie No. 2 permit application. <br />With two general guidelines in mind, the Division requests changes to the presentation of the baseline <br />surface water data for PR-12. The first guideline is that if Bowie No. 2 acquires a portion of the Bowie <br />No. 1 Mine permit area, then all of the liability for that portion of the permit area, including effects of <br />mining on the surface water regime, will need to be transferred to Bowie No. 2. Therefore, the <br />monitoring periods for the baseline surface water data should be as close as possible to the time of the <br />initial permit approval. <br />The second guideline is that "seasonal variation" for surface water is generally more sensitive than that <br />for deep ground water so baseline surface water data should include all 4 seasons, if possible. If data <br />sampling is inconsistent and four consecutive sampling seasons are not possible, then the gaps <br />between sampling periods need to be as short as possible to minimize annual variations in <br />precipitation and the effects from mining that occurred between the periods of sampling. <br />Based on these two guidelines, the Division has the following comments: <br />4