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~.9 , <br />.~ <br />Page 2 <br />Pete Evans <br />November 19, 1980 <br />9. The applicant has proposed to backfill and leave sediment ponds following <br />reclamation because dam removal would damage the established flow <br />reyime. (The applicant has not described how the dams would alter the <br />flow reyime during operations, nor how their removal would disrupt <br />the established flow regime.) The sediment pond regulations specifically <br />require that ponds be removed, and the site be regraded and revegetated, <br />unless the pond is upgraded to rneet permanent impoundment performance <br />standards. The applicant should revise the reclamation plan to include <br />pond removal. <br />5. The applicant has proposed to leave their mine benches following operations <br />rather than reclaiming them to approximate original contour. Regulations <br />to not require undergroirrrd mines to restore approximate original contour, <br />provided that all highwalls and depressions are eliminated, and the <br />requirements of 4.05, 4.06, 9.09, and 4.15 are met. The permit <br />application should be revised accordingly. <br />6. When subsidence effects have been analyzed to Jim Pendleton's satisfaction, <br />the discussion of probable hydrologic consequences should be updated <br />accordingly. <br />7. I have not reviewed the proposed surface and ground water monitoring <br />program. Until the Division has resolved any AVF issues and is satisfied <br />with the applicant's statement of probable hydrologic consequences, <br />the adequacy of tine hydrologic monitoring program cannot be assessed. <br />8. The applicant should discuss the possible effects that pumping ground <br />water from Stevens Culch would have upon the hydrologic regime of <br />Stevens Culch. This should be included in the discussion of probable <br />hydrologic consequences. <br />/k <br />