2016-12-19_REVISION - C1982057 - Laserfiche WebLink

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4.) Tab 18 in the PAP needs to be updated to correct the statement on page 2 of this section that all ponds, with the exception of Ponds 005 and 006 will be reclaimed. Response: Page 2 of Tab 18 has been updated with the pertinent information requested relative to the status of the ponds after mining has ended. This updated page has been included in this submittal. 5.) Tab 19 of the PAP needs Table 19-1 to be updated to reflect the current status of the reclamation schedule. Response: Table 19-1 has been reviewed and updated to reflect the current reclamation status and schedule. A copy of the revised Table is included with this submittal. 6.) Although no new mining activity is planned for this permit term, please assure that the plant species of concern are up-to-date with the current list (Rule 2.04.10(5)). The CNHP has updated their species of concern in 2013 and 2014 (1vww.cnhp.coloradostate.edu). Response: The PAP information on TES plant and animal species has been reviewed and updated consistent with current listing information. Copies of the updated PAP information are included in this submittal. 7.) Please assure that the evaluation of threatened and endangered species of concern is up-to-date with the most current list as well (Rules 2.04.11(4) and 2.05.6(2) (a) (iii) (A)). Response: Please see previous response. 8.) A permit commitment requires that SP re-initiate specific water quality parameters at least one-year prior to final bond release application. As the reclaimed areas at the mine are approaching eligibility for Phase III releases, the Division reminds SP of this permit commitment (PAP, Tab 15). The parameters of concern are applicable to both ground water and surface water monitoring. Response: SP is aware of the commitment to re-initiate sampling for specific water quality parameters for at least one year prior to application for final bond release. SP anticipated submitting final bond release in late 2016 for eligible areas. With the anticipation of final bond release, SP re-initiated sampling for specific water quality parameters during the 2014 and 2015 water years. 9.) Evaluation of hydrologic data from quarterly DMR's and AHR's to calculate yearly averages for parameters sampled at CDPS discharge points, the Division finds that the two data -sets generate different results. Averages for parameters such as flow, pH, and total dissolved solids are presented in the data (or calculated by the Division), and these averages differ by as much as 10 percent between a DMR and an AHR. Please explain why the results from the two data -sets are not equal. Response: AHR's are generated from the same reports as the DMR's. DMRs are prepared and submitted quarterly, and the 30 -day average is generated by taking the highest of the three monthly averages within the corresponding quarter, per the applicable CDPHE guidelines. The AHR reflects a true average of all data from the entire year. If the DMR 30 -day (high) averages are compared with averages calculated from all data for the AHR, they will not match because the DMR averages effectively "throw -out" the lower monthly averages, skewing the data to the conservative (high) side. 10.)Tab 17, page 17 of the PAP. The Division's copy of this page shows that there have been hand-written corrections to the values used in the equations of this section. Please review this section and provide corrected values. Response: An error in calculating the projected TDS of Dry Creek for modeling was found on page 17 of Tab 17. This error has been corrected and page 17 has been updated with the corrected calculations. The revised page 17 is included in this submittal. 11.) The Division has updated the reclamation cost estimate associated with the Seneca HWpermit. The updated reclamation cost liability for the Seneca HW Mine is $4,046,578.00. ........... Seneca Property, LLC currently has a surety bond in the amount of $5,818,456. 00.