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Once the Seneca IIW Mine has received final bond release, Seneca Property, LLC anticipates that the property
<br />will be sold, and the impoundment maintenance responsibilities (under the existing agreement) will be transferred
<br />to the new landowner(s) as part of the deed to assure future maintenance. For any interim period, SP will inspect
<br />and maintain the impoundments consistent with the existing maintenance agreement.
<br />3a) The operator's commitment to maintain the permanent ponds is included in the permit text. No maintenance
<br />agreements signed by landowners were provided. Although this commitment in the permit complies with Rule
<br />3.03.1(3)(c), the Division is confused by SP's statement that maintenance agreements for permanent ponds will be
<br />obtained prior to sale of the property. Only Pond 006 is located on land controlled by Seneca Property's parent.
<br />Pond 005 is located on property that is owned by Salt River Project. Pond 009 is located on property owned by
<br />the U.S.Bureau of Land Management. Pond 015 is located on property previously owned by John Ricks Family
<br />Trust. The Division has been informed that this property has changed hands, but SP has not updated the new
<br />ownership on maps, in the permit text, or with landowner agreements for long-term maintenance of Pond 015.
<br />Pond 006 is located on property owned by the Friederich family. Pond 017 is located on property owned by new
<br />owners to the Ricks' property. Surface Ownership map, Exhibit 3-1, in permit was last updated with SO -2, and
<br />dated 121112015.
<br />Response 3a: SP has attached a draft landowner pond maintenance agreement, which we propose to provide to
<br />the affected landowners for review and signature. On completion of the landowner outreach on the pond
<br />maintenance agreements, SP will provide the CDRMS with copies of the signed agreements. In response to the
<br />concern noted in this comment and Comment 12 re: updates to ownership information, SP has updated the
<br />relevant Tab 3 text, appendices, and maps, and the revised materials accompany these responses for replacement
<br />in the PAP (changes include the transfer of properties from John Ricks Family Trust to Steamboat Partners, Ltd.
<br />and from William L. and Kathleen A. Schlingman to Steven M. and Teresa M. Vestal).
<br />10) Tab 17, page 17 of the PAP. The Division's copy of this page shows that there have been hand-written
<br />corrections to the values used in the equations of this section. Please review this section and provide
<br />corrected values.
<br />Response: An error in calculating the projected TDS of Dry Creek for modeling was found on page 17 of Tab
<br />17. This error has been corrected and page 17 has been updated with the corrected calculations. The revised page
<br />17 is included in this submittal.
<br />IOa) SP resubmitted page 17 of Tab 17, with the same error included. The Division restates its concern
<br />regarding this prediction in the PHC:
<br />In the Probable Hydrologic Consequences section (PHC Tab 17), page 17 includes a prediction of the impact of
<br />mine discharges on Dry Creek. The text states that the aquifers combined will produce an estimated 4,806,953
<br />gal/day into the mine pits, and this will be discharged to Dry Creek. This very large value is used in calculations
<br />in the PHC. Please identify the source of the value of 4,806,953 gal/day.
<br />Based on 4,806,953 gal/day, the calculated value of 0.02 cfs appears to be incorrect. The Division has
<br />calculated 4,806,953 gal/day to equal 7.44 cfs. This should be corrected on page 17 of the PHC, and the
<br />related calculations (based on this flow rate) revised accordingly.
<br />Response 10a: The previously submitted revised page did include the referenced correction, however it was
<br />easily missed because although a minor text revision, it makes a significant difference in the calculations. The
<br />correction is in the units on the flow amount of 4,806,953. The previous text showed the units as gal/day, which
<br />was corrected in the revised text to gal/yr. The value of 4,806,953 gal/yr is the combined total of maximum flows
<br />for the year 2001 from the Wadge Overburden Aquifer (2,317,500 — Table 17-2) and the Wadge Coal Aquifer
<br />(2,489,453 — Table 17-3) — (2,317,500 + 2,489,453 = 4,806,953). Conversion of 4,806,953 gal/yr to cfs results in
<br />the referenced figure of 0.02 cfs. A copy of the previously submitted revised page accompanies these responses
<br />for reference.
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