Laserfiche WebLink
Northfield Mine Permit Review <br />October 2, 2007 <br />17, 17a and 17b. <br />Page 2 <br />Northfield updated and improved Exhibit AB the Hydrologic Monitoring Plan as <br />requested. The well mitigation plan was incorporated as Item VII and the proposed <br />domestic/irrigation wells that may be included in monitoring program were summarized <br />in the new Table 6 of Exhibit AB. Some but not all of the detail information requested in <br />item 17 was provided for these wells in Table 6. As requested in items 17a and 17b well <br />permit numbers 222887, 79354 and 3759 have been included in the proposed monitoring <br />plan. <br />It is still unclear which well permit holders have granted the right to enter their properties <br />to perform monitoring. If these wells aze to become part of the monitoring plan as <br />proposed, then details on permission and access to the wells should be worked out and <br />agreed upon up front. The details of the monitoring plan must be clearly stated in the <br />permit text so that baseline conditions can be established prior to mining disturbance. <br />34. Northfield appropriately updated Tables 1 and 2 of Exhibit AB. In item 34 the Division <br />also asked that access to the proposed private wells be determined for those wells to be <br />included and that those wells be added to Exhibit AB under Section VI. Northfield did <br />update Exhibit AB with a proposed well list (see item 17 above). However, it does not <br />appear that the access has been determined. Northfield indicates in their response to item <br />34 that a copy of the access letter is provided in Exhibit AB. The copy of Exhibit AB that <br />I received did not contain any access letter. A private well permit holders release was <br />referenced in Section VI of Exhibit AB as Exhibit A but this was not included with the <br />Hydrologic Monitoring Plan. It does not appear that access and permission to monitor <br />specific private wells has been resolved. <br />34a. Northfield has committed to monitoring the Chandler Creek alluvium as a compliance <br />point for the parameters listed in Tables 1 through 4 of the Basic Standards for Ground <br />Water. As stated in my original adequacy question, I still believe that it would be prudent <br />to establish the baseline water quality conditions for the Basic Standards (Tables 1 <br />through 4) at all of the monitoring well locations not just the Chandler Creek alluvium. <br />The sampling and analysis plan could be easily scaled back to the suggested parameters <br />of Table 2 in Exhibit AB after the baseline collection period. <br />Table 4 was added to the Hydrologic Monitoring Plan of Exhibit AB to provide the <br />consolidated Basic Standards parameter list. The list as provided in Table 4 is acceptable, <br />but should be footnoted indicating that the inorganic constituents will be analyzed for the <br />dissolved concentration only. <br />Please let me know if you have any questions regarding my review. <br />C: Denver File <br />