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head change in diatreme". The vertical scale of the figure is too small to show <br /> the requested details. The Division did not request the Carlton Tunnel elevation <br /> be shown on this cross-section, as it is displayed on other figures submitted. <br /> Please increase the vertical scale of the figure and show more detail for the <br /> requested features. The features of interest occur from surface to approximately <br /> 9,500 foot elevation (below the surface).Additionally,please ensure all features <br /> are labeled on the figure, including Grassy Valley Creek and the approximate <br /> location of the monitoring wells. <br /> Response: Please see responses from Adrian Brown Consultants (ABC)provided in <br /> Attachment 5. <br /> 5. The cross-section submitted on December 9th as Plate 31 does not show enough detail <br /> to adequately display the nature of the Grassy Valley perched aquifer in relation <br /> to the areas identified on Plate 9 (Rev. I)as"post-mining Grassy Valley capture <br /> zone"and"area where drainage tunnels do not cause significant head change in <br /> diatreme". The vertical scale of the figure is too small to show the requested <br /> details. The Division did not request the Carlton Tunnel elevation be shown on <br /> this cross-section, as it is displayed on other figures submitted. Please increase <br /> the vertical scale of the figure and show more detail for the requested features. <br /> The features of interest occur from surface to approximately 9,500 foot elevation <br /> (below the surface). Additionally, please ensure all features are labeled on the <br /> figure, including Grassy Valley Creek and monitoring wells, if appropriate. <br /> Response: Please see responses from Adrian Brown Consultants (ABC)provided in <br /> Attachment 5. <br /> Appendix 2—Hydrologic Evaluation, CC&V/December 2015 <br /> Table 2-1 —Water Quality Monitoring Parameters <br /> 6. The Operator's response to item no. 59 proposes groundwater numeric protection <br /> levels (NPLs) for five parameters (Total Sulfate, pH, Dissolved Manganese, <br /> Dissolved Zinc, Weak Acid Dissociable Cyanide) for each of the drainages <br /> where compliance monitoring is required (Arequa Gulch, Grassy Valley, <br /> Vindicator, Wilson Creek, Squaw Gulch, and Poverty Gulch). Some of the <br /> proposed NPLs are not compliant with the requirements of Colorado Department <br /> of Public Health and Environment (CDPHE) Water Quality Control <br /> Commission (WQCC) Regulation No. 41 — The Basic Standards for Ground <br /> Water. Therefore, pursuant to C.R.S. 34-32-115(4)(c)(I) and (g); C.R.S. 34-32- <br /> 116(7)(c), (g) and (i); Rule 3.1.7(1)(a), (c) and (d); and Rule 3.1.7(4), the <br /> Division's approval of AM-11 cannot constitute approval of the proposed NPLs. <br /> The Division understands the complexity of the issue and the time needed for <br /> resolution is beyond the scope of AM-11. Please review the enclosed Request <br /> for Demonstration of Compliance letter from the Division, and commit to <br /> submitting the required information within 90 days, due March 28, 2017. <br /> 7 <br />