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<br />(. <br />7. The application mentions that TDS concentrations increase below the mine as <br />compared to upstream concentrations. What is the major factor(s) contributing to <br />this change? What effects vrill developing the refuse pile have on TDS and other vrater <br />quality parameters. Wfiat is the significance and duration of these effects. <br />8. Page 167 states that "ultimately all vrater currently"discharged vrill be consumed in <br />the mining operation". The applicant should calculate the maximum use of vrater by the <br />mine and discuss the effects of this use on the flows .in North Thompson Creek. Could <br />dovrnstream users be impacted by this water use? If so, the application must include a <br />plan for mitigating these impacts. <br />9. At cessation of mining, flour in Thompson Creek could be reduced as much as 0.3 cfs by <br />your calculations. Considering that base flour in September was reported at 0.6 cfs this <br />could have a significant impact on fish, aquatic plants and animals as well as dovrnstream <br />users. The application should discuss .the magnitude of these impacts and methods that <br />could be used to mitigate these impacts. In addition if vrater vrill be made available for <br />replacement we will need to knovr its quality, its course and location. <br />10. The applicant should submit all NPDES monitoring data collected to date. <br />11. The application should contain written proof that vrater rights for mine water <br />consumption have been obtained. <br />12. The applicant should note that the adequacy of the surface and ground vrater monitoring <br />plan will be revievred later in the review of the application when more baseline data <br />is submitted and revievred. <br />13. The text page 168, states that the Middle sandstone aquifer is hydraulically <br />independent from the other 3 vrater-bearing zones based on field water quality data and <br />water pressure and therefore will not be affected. The applicant should provide a <br />discussion as to how this conclusion vras reached and the data used to reach this <br />conclusion. <br />14. Possible impacts to alluvial aquifers, The Rollins Sandstone, the 240 foot Sandstone <br />and the 80-foot Sandstone should be discussed. <br />Subsidence Survey, Subsidence Monitoring and Subsidence Control Plan <br />Section 2.05.6(6) <br />The response on page 173 of the application is insufficient to fulfill the requirements <br />of this Section. Please read the attached memo from Jim Pendleton of our staff and <br />re-address this Section. <br />Requirements for Permits f^r Special Categories of Plining <br />Section 2.06.8 - Surface Coal Mining and Reclamation Operations on Areas or Adjacent <br />to Areas, Including Alluvial Vallev Floors <br />1. The Division requests that the applicant submit a USGS topographic map that delineates: <br />(a) the permit area; (b) the life of mine extent; and (c) the AVF reconnaissance level <br />study area. The AVF reconnaissance level study should then encompass the ground and surface <br />vrater area adjacent to these proposed and existing vrorkings. <br />2. The applicant is hereby advised that CRS 1973, 34-33-114(2)(e)(II) allows an exemption <br />from the requirements of Section 114(2)(e)(I), if, in the year preceeding August 3, 1977, <br />mining operations either produced coal in commercial quantities and vrere located within or <br />adjacent to an alluvial valley floor, or had obtained permit approval to conduct coal <br />