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reviewed and we feel it is representative of the conditions expected on the eastern border of Federal Lease <br />C-079641. Areview of Section 2.7.1, Structural Geology was completed as well and, that section describes <br />a far broader area than is included in the Trapper Permit Area. Trapper believes that the information <br />included in the current permit adequately describes the field conditions to be found in this area. <br />24 December 2018 DRMS: If no additional mining is being proposed in the PR -7 <br />expansion area, the Division accepts Trappers response. The stipulation should <br />remain in place at this time and be reevaluated upon future revisions that are <br />proposing to expand mining into the above referenced area. <br />Rule: 2.04.7 (1) (3) (4) Hydrology Ground Water <br />Hydrology descriptions and Mitigation of Impacts of Mining for the N -pit <br />redisturbance area, are not adequately described as required by Rules <br />2.04.7(1)(b) and 2.05.6(3)(a) and (b). <br />6. Please provide additional text specific to the N -pit. This should meet the <br />requirements of the above stated rules and specifically address these rules in <br />relation to anticipated drawdown due to pit dewatering, anticipated rebound <br />of groundwater elevations, affects to surrounding wells and springs, ground <br />water quality, and storage and recharge capacity. This is a redisturbed area, <br />however the disturbance is going deeper than previously mined and will <br />create a larger volume of disturbance and increased permeability. <br />Trapper Response to Comment 6A: New permit narrative pages 2-462n, 2-520xx, 2-523z and 2-524h <br />are enclosed to address the ground water issues outlined above specific to proposed N Pit. Table of <br />Contents page 1-5 is revised and enclosed to reference these new pages. <br />24 December DRMS: The additional pages have been reviewed and meet the rule <br />requirements, no additional adequacy items are requested at this time. <br />Rule: 2.04.7 (2) Hydrology Surface Water <br />This is a review of the surface water related sections of the Hydrology Conditions <br />and includes: <br />a. Surface water flow rates. <br />b. Water quality information. <br />c. Waterbody locations and discharge into water bodies. <br />The above rule is adequately addressed. However, DRMS possesses the following <br />questions regarding TMI's newly issued NPDES discharge and monitoring <br />requirements as per CDPHE. <br />6B. As some discussion is included regarding past NPDES permits, would it be <br />appropriate to discuss on revised page 4-241a the recent changes to <br />monitoring and analyte sampling put in place by CDPHE in 2018? <br />Trapper Response: We received a draft NPDES permit renewal from WQCD on March 8, 2018. We <br />responded with 50 pages of questions and concerns. Agreement on a final renewal is still far from <br />being finalized. Thus, discussion on page 4-241 a concerning changes to monitoring and analyte <br />Trapper PR9 2"`' Adequacy Prepared by: R. Reilley, LISP, M.S. Page S <br />Date: December 2018 <br />