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Dan ;tachews - 2 - March 11, 1983 data during operations and reclamation. The plan should include surface water monitoring on Grassy Creek, alluvial ground water monitoring, mon- itoring pond discharges, and the monitoring of spring flow and spoil water, if appropriate. (Dan - One of our hydrogeologists should also review the application's conclusion of "no ground water". I have seen no indication of a well survey for the permit and adjacent area. The possibili.tyof developing a spoil aquifer following mining should also be considered before we approve the proposed permanent impoundments.) Permanent Impoundments The applicant has proposed, at the landowner's request, to leave all of the sediment ponds as permanent impoundments. The regulations allow these ponds to remain if certain specific demonstrations concerning water rights, water quantity and quality, and pond design are made (Rules 2.05. 3(4), 4.05.9, and 4.05.17). 1. The applicant should provide a discussion demonstrating that the use of water from these impoundments would be in compliance t•iith State Law. 2. For each pond to be left as a permanent impoundment, the applicant must provide a detailed design plan prepared by, or under the direction of, and certified by a qualified registered professional engineer. The plan must show that the pond would meet the appropriate design standards of Rule 4.05.9 (1)(e), and that any permanent diversions associated with the pond would meet the standards of Rule 4.05.3. The plan should spec- ifically identify any renovation required to convert the sediment pond or ditches to the standards for permanent impoundments and ditches. 3. For each permanent impoundment, the applicant should provide sufficient hydrologic analysis to show that water levels would be sufficient stable to support their intended use. It is uncertain if stock ponds located high on the hillsides would receive sufficient runoff to accumulate water. 4. The water quality for ponds receiving only surface runoff should be sufficient for stock water use. However, ponds receiving water that has passed through the spoil may not have a suitable water quality. For any permanent impoundment that would receive spoil water (either because the pond is in contact with the bottom of the pit and ~•iould receive unsaturated flow or because the spoil would develop an aquifer and the pond would intersect the past-mining spoil water levels), the applicant should provide water quality predictions demonstratino the suitability of the water for stock water use. (Dan - I have reviewed this section for compliance with the permanent impoundment requirements and not as sediment control ponds. Ply concerns are mostly in addition to those you have already identified. Also, the presence of the permanent impoundments could affect the stability of the post-mining surface and the natural hillslopes. Jim Pendleton should consider these geotechnical concerns during his revie~•~.)