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Dudash <br />August 13, 2010 Page 2 <br />As indicated in the revised application two of these bedrock groundwater wells will be transferred <br />to the Bowie No. 2 permit. In BRL's responses to our adequacy review for PR -12 at Bowie No. 2 <br />they indicated that five potential monitoring wells (including the two proposed for transfer) are not <br />appropriately constructed to monitor the B -Seam or the saturated zone above the B-Seam. This was <br />confirmed in our meeting on July 28` regarding Bowie 1 & 2 groundwater with BRL <br />representatives, Jim Stover, and me. I requested the well completion information for the wells <br />that are identified by Jim Stover in his response to item 51 of PR -12. All of these wells listed in <br />Table 4B (except DH -62 which I have no information about) have poor completions and are <br />perforated at multiple intervals in the same borehole. Jim Stover did not provide any water <br />quality data from these wells or information on when they were sampled during our meeting, but <br />indicated that he may be able to retrieve water quality information. So, I am a little confused <br />about whether or not good reliable baseline data exists for the deep bedrock groundwater wells <br />(which is pertinent to how we move forward with the Bowie No. 2 Mine Plan with PR -12). <br />In summary, the operator has been relieved from bedrock groundwater monitoring at Bowie No. <br />1 through previous revisions. There appears to he adequate information for shallow colIuvial and <br />alluvial wells. On Table 4B in the PR -4 application twelve (12) alluvial /colluvial wells are <br />indicated as still being monitored presently and I assume they will continue to be part of the <br />approved monitoring plan for Bowie No. 1. <br />I believe the deep bedrock groundwater description and associated baseline data discussion needs <br />to be clarified and I have the following comments. <br />1. Under Groundwater Monitoring -Bowie No. 1 Mine and West Mine Site on page 114, the <br />first sentence should be clarified. BRL states that "The Bowie No. 1 Mine East and West <br />Mines are located several hundred feet above the water table of the area." This is not <br />consistent with our understanding of the groundwater regime of this area. From this <br />description it seems that BRL is describing the deep bedrock groundwater, but deep <br />bedrock groundwater is not typically associated with a "water table" and no further <br />description is given. If groundwater is confined by overlying impermeable rock <br />formations (which I think is the case with the deep bedrock groundwater in this area) the <br />well water levels that rise in the well represent a pressure level and not a water table. <br />Bowie No. 2 has recently prepared a potentiometric map (Map 10 -B, B -Seam <br />Potentiometric Surface Map) of which a portion overlaps this area in question. The water <br />levels are shown to be deeper than several hundred feet. Please clarify what is meant by <br />"water table of the area" on page 114 and provide descriptions of the occurrence of deep <br />bedrock groundwater and the shallow alluvial and colluvial groundwater for inclusion <br />into the application. This needs to be better characterized so that what we can transfer <br />this information to the Bowie No. 2 Mine and have a better understanding of what <br />baseline information is available and what additional data may be necessary. <br />2. Under Past Groundwater Monitorin�rmit and Adjacent Areas on pages 120 and 121 a <br />discussion of bedrock groundwater monitoring is provided. BRL initially states that <br />