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<br />-6- <br />recharge of the reclaimed spoils material will enable rapid recovery of the <br />original storage volume of the undisturbed overburden aquifer from the <br />temporary dewatering due to mining. These conflicting statements should be <br />revised to clarify this situation with regard to dewatering of the overburden <br />aquifer. <br />2. Recharge Capacity <br />The post-mining recharge rate of the overburden aquifer 1n the Mine No. <br />3 area was estimated by the applicant to be 140 acre-feet/year as compared to <br />the recharge rate of 9.0 acre-feet/year for the overburden aquifer in the <br />pre-mining condition (page 2.05-167). This raises the question of water <br />balance. The applicant states that water•lnfiltrating into the backfilled <br />mine pits will flow downslope to the highwall where it will provide recharge <br />to the undisturbed overburden aquifer. Supporting calculations are needed to <br />verify that the undisturbed overburden aquifer is capable of transmitting this <br />increased volume of recharge water, so that spoils water from the reclaimed <br />pits does not eventually discharge from the toe of the pits to the surface <br />water or shallow alluvial aquifer systems. <br />3. Solute Leaching <br />In an attempt to quantify the amount of solute leaching from backfilled <br />mine pits, the applicant performed a leaching study on overburden material <br />collected from the Eckman Park Mine. One of the most important results of a <br />leaching study such as this is to estimate an anticipated "worst case" value <br />for total dissolved solids concentration of leachate percolating through the <br />reclaimed spoils pits. An anticipated "worst case" TDS value for spoils <br />leachate should be included in this section. Also, the raw data compiled from <br />the leaching experiment should be included in the permit application. <br />4. Solute Transport <br />The applicant has qualitatively discussed the mechanism of increased <br />dissolved solids transport from the backfilled mine pits to the undisturbed <br />overburden aquifer system. However, a quantitative interpretation of effects <br />has not been presented. A numeric projection of anticipated Impacts of spoils <br />water discharge on the ambient hydrologic system should be produced and <br />supporting data and calculations should be included in the permit application. <br />SURFACE WATER EFFECTS <br />1. Runoff and Erosion <br />A quantitative evaluation of the anticipated increase in runoff and <br />erosion rates for all disturbed areas should be presented along with <br />supporting data and calculations. <br />2. Sediment and Dissolved Salt Load <br />The applicant should include a numeric estimation of the change 1n <br />sediment and dissolved salt load on receiving streams due to existing and <br />proposed mining activities both during mining and post-reclamation. <br />