2018-04-02_REVISION - C1982056 - Laserfiche WebLink

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maps were not found with regard to other mine openings. Please either provide this information or update Section 2.05.4(2)(g) of the permit to cite the location of this information within the Permit. Response: - All mine openings are identified in Section 2.05.3(2) (pages 2.05-11.1 and 2.05-11.2), described in Section 2.05.3(3), and their locations shown on Map 24 (Mine Facilities and Freshwater Systems). The detailed descriptions provided on pages 2.05-119 through 2.05-121 adequately describe the plugging and sealing methods to be used to secure the various types of mine openings. The addition of cross-sections would not provide any additional relevant information, would not necessarily be representative, given differences in the size and type of mine openings, and is not necessary or appropriate. 2.05.4(2) (h)- Compliance with Clean Air Act, The Clean Water Act and other applicable water quality laws, regulations and health and safety standards 52. DRMS was unable to locate Exhibit 10 NPDES Permit CO -0036684 and Exhibit 5 NPDES Permit CO - 0027154. Please address the following: a. Please either inform DRMS where the afore -mentioned exhibits reside in the Permit or provide these exhibits to DRMSfor inclusion in the Permit b. Are all the permits (MPDS and air pollution) still active and necessary? If they are no longer active please provide language in the permit stating that a specific permit number is no longer active and has been terminated Response: - Based on the current Table of Contents, Exhibit 10 should be; Geochemical Analysis of the Wadge Seam, included in the confidential appendices, and Exhibit 5 should be; Pasture Management Practices in the Twentymile Park Area. Under the response to Comment 10, TC has updated the information on other permits applicable to the Foidel Creek Mine operations. In reviewing the PAP, several discharge permits appear to be scattered among the Exhibits. In order to simplify location and referencing of these documents, all discharge permits have been consolidated in Exhibit 30, and the Table of Contents has been updated. All updated or revised materials relating to this comment accompany these responses for insertion or replacement in the PAP. 2.05.6(3) (a) (i), (iii), and (iv) — Protection of the Hydrologic Balance 53. Sampling frequency issues pointed out in the DRMS Review of the 2014 Annual Hydrology Report, specifically items 11 and 16 concerning Exhibit 14. TCC will need to address any item where a specific monitoring requirement was not met. Please either submit the data or explain why the data was not collected. Please also address any inconsistencies in sampling frequencies for 2015-2017. Response: - TC responded to the Division's comments on the 2014 Annual Hydrology Report by letter dated 05/04/16 (copy attached for reference). With the exceptions of adverse field conditions which precluded field data collection prior to mid-April, changes in stream conditions affecting data accuracy (Sites 8 and 900), the noted problems with a gauging station (Site 27A), and questions about the continued need for the Jones well, the response addresses the Division's stated questions or concerns. Despite efforts to eliminate the beavers upstream of Sites 8 and 900, they have persisted, so the same considerations apply to ongoing monitoring for these sites. TC has continued to conduct direct monitoring of flows for Site 27A and the upstream site (Site 305), where ongoing stream erosion and livestock use are considerations relative to re-establishment of regular gauging stations. TC is currently in negotiations with the owners of the Jones Well to try to establish a good long-term water supply from a deep groundwater aquifer, and the outcome of these efforts will determine whether or not the Jones Well will need to be maintained as a monitoring well (Jones water supply well is not currently being used as TC is providing hauled water to a cistern). 54. TC will need to evaluate the concerns identified in item number 24 of the DRMS Review of the 2014 AHR data and the PHC (section 2 05 6 3 of the permit) regarding surface hydrology impacts. TC will need to address the following item: a. For the lower reaches of Middle Fish and Trout Creek, the projected average conductivity sulfate and TDS levels for 2009 to 2015 contained in Exhibit 32 do not appear to be reflective of the average levels reported in the 2014 AHR. The averages reported for these parameters exceed the average projected amounts. TC will need to evaluate these constituents and update the Probable Hydrologic Consequences section of the permit and assess the negative impacts of these elevated constituent levels. Please include current data up through 2017 in this update.