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Marcia Talvitie <br />January 2, 2011 <br />Page 3 <br />7. WFC has done a good job with their initial baseline data collection efforts for ground water <br />information with regard to monitoring well depths and locations. These are consistent with <br />the discussions held with WFC regarding groundwater monitoring sites during the planning <br />phases of this project. However, additional down gradient monitoring and a point of <br />compliance well(s) may be required. The Division agrees with WFC's assessment that there <br />are no current users for the relatively small amount of groundwater that is currently moving <br />through the shallow bedrock zones, overburden and coal toward the crop line to the <br />southwest. Because this groundwater is potentially usable it must be monitored and the <br />extent and magnitude of any mining impacts must be determined. Given the information we <br />now have as provided on geologic cross - sections, piezometric level maps, and the <br />disturbance boundary as shown in the application the Division believes that one additional <br />group of nested wells may be warranted. The reason for this is that the full extent of the <br />disturbed area is not being monitored in the downgradient direction (i.e., the southwest end <br />of the southernmost mineable block). WFC has other existing monitoring wells in this <br />general vicinity that may be suitable and could potentially be included in the monitoring <br />plan for this purpose. <br />Additionally, there is no discussion of groundwater points of compliance for the proposed <br />project. Please review your ground water monitoring program specific to establishing a <br />groundwater point (or points) of compliance at the New Horizon North Mine, and specify <br />which well or wells will be available as point of compliance well(s). The PAP should <br />address the need for points of compliance and be updated accordingly. The Division <br />believes that a meeting would be beneficial to clarify and discuss our questions regarding <br />the need for additional downgradient monitoring and point(s) of compliance. <br />On pages 6 and 8 water quality standards are referenced including drinking water, <br />livestock and agricultural quality standards. The appropriate standards to use are WQCC <br />Regulation No. 41 The Basic Standards for Ground Water. Please provide a reference for <br />the standards that are referred to on pages 6 and 8 and describe how they are being <br />utilized here. <br />9. Table 2.04.7 -3 is labeled 7.04.7 -3. Please correct this error. <br />10. The origin of the water quality standards listed on Table 2.04.7 -3 should be footnoted on <br />the table and further described in text (see Item 8 above). <br />11. On page 11 Springs and Seeps are described. There are three identified spoil springs at <br />the New Horizon 1 Mine as described but it is unclear what their current status is. This <br />should be added to the discussion. Please describe in detail the existing spoil springs at the <br />New Horizon Mine #1 include a discussion of whether or not they are still discharging and <br />whether or no they are being monitored. If applicable, add to the discussion the <br />approximate time that monitoring ceased for all spoil spring locations. <br />12. Please add a statement to the Springs and Seeps section whether or not there are any <br />naturally occurring springs within or adjacent to the permit area. <br />