2010-08-02_REVISION - C1996083 - Laserfiche WebLink

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17. On page 2.04-34 the existing text regarding perched groundwater has 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. This issue is resolved. BRL provided a corrected page 2.04-37 in the July 8, 2010 submittal. 18. On page 2.04-34 coal seam groundwater is described under Mesaverde Formation - Perched Groundwater. New discussion has been added regarding the potentiometric surface map of the D-Seam and new Map 10-B presenting the potentiometric surface of the B-Seam has also been added. It would be helpful and easier to follow if the discussion of the coal-seam groundwater was broken out into a new separate paragraph, and rather than reference the D-Seam potentiometric surface from HydroGeo's June 2008 report add a new Map 10-C for the D-Seam potentiometric surface. It also appears that the last paragraph on page 2.04-39 regarding the occurrence ofgroundwater in the coal seam should be added to this discussion and moved up to page 2.04-34135. If deemed appropriate, please make these suggested changes to the permit text. This issue is resolved. Revised pages 2.04-34 and 2.04-39 and revised Map 10B were provided in the June 1, 2010 submittal. 19. On revised page 2.04-34, reference is made to a HydroGeo June 2008 report in Exhibit 3 of Volume III. The Division does not have this report. Please inform the Division under which revision this report was incorporated into the permit application. This issue is resolved. Page 2.04-34 was revised in the July 8, 2010 submittal to delete the reference to the June 2008 report. Instead of the June 2008 HydrGeo report, the September 2008 HydroGeo report should be in the permit application. Please note that the decision document for PR-10 already placed the September 2008 HydroGeo Report into Exhibit 3 of Volume III of the permit application. Therefore, the proposed decision document for PR-12 will not include the September 2008 report in the list of revised pages and maps. 6