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Rationale for Recommendation to Approve 36 <br /> September 29, 2016 <br /> of disturbed land. The Applicant has incorporated these recommendations into the permit application. <br /> CPW did not provide any comments or recommendations specific to Gambel Oak. <br /> 42. Concern regarding Exhibit E—what other chemicals besides mycorrhizal solution or inoculant <br /> for bare root seedlings will be used for reclamation? <br /> (N.Reed) <br /> Mycorrhizal solution is a bare root treatment with live beneficial mycorrhizal fungi to inoculate the roots <br /> of bare root plants before planting. It provides the best possible conditions for the roots to become as <br /> effective during and after planting. The results are better survival and growth rates and less watering for <br /> all transplants. <br /> The Division has determined the permit application satisfied the requirements of Rule 6.4.5, and the <br /> applicable performance standards of Rule 3.1. The Applicant is not required to submit a list of chemicals <br /> to be used for reclamation. However, the permit application does include a hazardous materials <br /> management plan which was submitted in the adequacy review response on July 28, 2016. This plan <br /> provides a list of typical hazardous materials to be used and/or stored on site during construction and <br /> development. <br /> 43. Concern regarding Exhibit G—BBA memo -Page 5- what data needs to be collected to better <br /> determine whether groundwater would be encountered in southwestportions of mining area where data <br /> is not available? BBA memo - Page 6 — they recommend installation of two monitoring wells before <br /> mining begins to quantify and confirm groundwater changes are not occurring in the water supply <br /> wells west and east of the proposed mine-will the operator follow this recommendation? <br /> (N.Reed) <br /> The Applicant addressed this concern in the adequacy review response submitted on July 14, 2016, <br /> particularly in response to the Division's item no. 170. Per the Division's requirements, the Applicant has <br /> submitted a groundwater monitoring plan that includes monitoring of water quality and groundwater levels <br /> at four monitoring wells to be installed hydrologically upgradient and downgradient from the proposed <br /> mine operation in Little Turkey Creek valley and Deadman Creek valley. Groundwater is not expected to <br /> be encountered outside of the fractured areas (valleys). Actual impacts of mining will be monitored with <br /> the proposed monitoring wells, and the well locations proposed by BBA Water Consultants for outside of <br /> the productive fractured areas is difficult to access. For these reasons, the Applicant is not currently <br /> pursuing the monitoring wells outside of the fractured areas and will rely on the proposed monitoring <br /> wells within those areas near the creeks to monitor groundwater impacts. <br /> The Applicant further addressed this concern in the adequacy review response submitted on August 19, <br /> 2016, particularly in response to the Division's item no. 16. The application states that although <br /> groundwater is not expected to be encountered by the mining operation, if groundwater is encountered, <br /> the Applicant will notify the Division and DWR. If groundwater is encountered, the DWR will require a <br /> well permit, and the operation must comply with DWR requirements. The operation must also comply <br /> with all requirements of the Division,including revising the mining permit through the Technical Revision <br /> or Amendment process to address the interception of groundwater, if such occurs. <br /> 1313 Snerma, Sheet, Room 215, Denver, CO 80203 P 333.866 3367 F 303.83L8106 h'tp: /rniwno.5tate~ Co.tiS /�r.+.r�9o} <br /> John W, Hickertooper. Governor Ronert W R:,Ail[, Eycutr.e C:rector Virg r Brannon, Oir-c:}r> I N _ ? o)I <br /> . _ <br /> `� !sus>*+r <br />