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Mr. Guth <br />December 2, 2014 <br />Page 3 of 5 <br />augmentation plan for this water body has been approved by the SEO. Documentation may also be provided <br />to DRMS to show that adequate water rights have been committed to the SEO to account for this groundwater <br />exposure; however the site cannot be released until the permanent augmentation plan is approved. Please <br />address. <br />Section 5.2 of text does not specify the depth for topsoil replacement. DRMS suggests a minimum of 6" of <br />topsoil be replaced to facilitate revegetation efforts. Seed mix listed as "Table 2" in text, but Table appears to <br />be named Table 1. <br />Section 5.5.4 of the text mentions "earth dams" being constructed to impound reservoirs, but there is no <br />mention of these features on the reclamation map, and no information provided to describe size, capacity, <br />design, etc. SEO approval will need to be obtained BEFORE DRMS can approve the construction of any <br />"earth dams" within the permit. <br />Section 5.5.6 does not seem to differentiate between overburden and topsoil, however, DRMS rules require <br />that topsoil be segregated and maintained as a reclamation resource separately from other overburden material. <br />Please revise. <br />Section 5.5.6 also contains one sentence that states "weed control will be conducted on an as- needed basis.." <br />however, the weed control plan will require significantly more information, especially considering the <br />proximity to surface water bodies. Please include at least species anticipated to require control, and what <br />control measures will be implemented for each species during what times of yr. (mechanical/chemical types <br />and rates /etc..) <br />EXHIBIT G - Water Information (Rule 6.4.7): <br />DRMS does not believe that this operation as proposed; which intends to install four lined groundwater <br />reservoirs into the alluvial aquifer, can accurately make the statement as supplied at the introduction to this <br />section (G -1.1) of the amendment — especially when section 1.2.1 is titled "impacts to groundwater ". Please <br />revise. <br />Table listing water requirements for the project is listed as Table 4 in the text, but again, titled as Table 1 — <br />please correct. <br />Drawing C4 seems to indicate that there have been at least 20 borings installed on the northern part of the site <br />during 2013, but no data has been provided for them or any of the southern part of the site. Is there any <br />current or historic water level data for the Three Bells site? <br />Section 1.3.4 references four existing wells shown on figure G -1 with data included in Table G -1. DRMS has <br />been unable to locate these either of these items in the AM -01 submittal. Is there any well construction <br />information available for these existing wells? Figures 1 -10 of the groundwater modeling submittal also <br />appear to be missing. <br />DRMS rule 3.1.6(1) states that the prevailing hydrologic balance must be maintained both during and after the <br />mining operation for the affected land and the surrounding area. As previously stated, DRMS will also require <br />the installation, if not already present, of a sufficient number of properly located and constructed piezometers <br />to monitor for possible excessive groundwater mounding and/or shadowing and off -site impact. Installing <br />monitoring wells after a groundwater problem has been indentified has not been a viable strategy in the past - <br />historic data is required for any useful groundwater impact evaluation. <br />