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Brock Bowles <br />Page 4 <br />May 26, 2015 <br />4.24 Operations In Alluvial Vallev Floors <br />A review was conducted of permit section 2.06.8, the Division's AVF sections of the RN6 Findings <br />document, the operations hydrologic monitoring plan and pertinent sections of the 2010 to 2014 Annual <br />Hydrology Reports. <br />4.24.1, Scope — No comment <br />4.24.2 Essential Hydrologic Function- Regarding Rapid Creek AVF, it does not appear surface <br />disturbance has occurred within the AVF. This AVF is outside of the permit area. The source of the <br />water for this AVF is the surface water stream system of Rapid Creek and Cottonwood Creek. No <br />disturbed runoff or mine water is approved to be discharge to Rapid Creek. Rapid Creek appears to have <br />been undermined. The RN6 findings document indicates that subsidence effects are not expected in this <br />area. Given this it does not appear mining should impact the essential hydrologic function of the Rapid <br />Creek AVF. <br />Regarding the Colorado River, The SL8 application indicates that all sediment ponds have been reclaimed <br />at the mine. SCC submitted demonstrations that each pond can be removed prior to conducting <br />reclamation and are included in Appendices 14-2 and 14-3 in the permit. Given this, surface water <br />discharge from the site should not impact the essential hydrologic function of the AVF. Also, the <br />Division has previously found that surface waters which could be and were used to irrigate the non - <br />exempted alluvial valley floor would be diverted from the Highline Canal. Water in the Highline Canal is <br />diverted from the Colorado River approximately one mile upstream of the mine disturbance. The <br />Highline Canal was not projected to be affected by subsidence or by mine discharges. Therefore, the <br />quantity and quality of surface water which supplies the AVF would not be affected by the proposed <br />operations according to the RN6 Findings. Also according to the RN6 findings, Agricultural activities on <br />the lower areas of the lower terraces and floodplain of the Colorado River may be marginally subirrigated <br />by alluvial groundwater. The RN6 findings document states, "The proposed operation would not affect <br />the quantity of flow in the Colorado River stream/alluvial aquifer system. Disposal of coal refuse <br />material in an adjacent area, and the discharge of mine water from underground workings could affect <br />water quality. The Division has assessed the possible effects of these activities and has not identified any <br />significant change in water quality." These findings appear to still apply based on my review. <br />4.24.3 Protection of Farming and Water Supplies- Rules 4.24.3(1), (2) and (3) do not apply to those <br />lands which were identified in a reclamation plan approved by the State prior to August 3, 1977, <br />according to subpart (4) of this rule. Please see Section 2.06.8 above for details. The majority of the <br />mining disturbance at the site falls within this exception area. The AVF impacted by the UTL was Phase <br />III bond released with SL7. No issues were identified. <br />