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Permit Revision Adequacy Comment Response <br />November 30, 2004 <br />Page 23 of 24 <br />• 116. Rule 2.06.8(4)(a)(iv) also requires submittal of information to demonstrate that the <br />operation would not materially damage the quality of water in surface or ground water systems <br />that supply identified alluvial valley floors. Please address within the AVF section of the <br />application, the potential for minewater dischazge to affect water quality suitability of waters <br />used to irrigate the identified alluvial valley floors on the North Fork of the Gunnison River. <br />The assessment should be based on worst case projection for both the short term (maximum <br />dischazge projected during operations) and the long term (maximum dischazge from flooded <br />workings via designed dischazge and other connections between the flooded workings and the <br />North Fork stream/alluvial system). The projections should incorporate the effects of proposed <br />SOD mining, and the evaluation should include a quantitative worst case assessment of the <br />probable increase in specific conductance of waters in the North Fork downstream from the <br />mine workings discharge areas. <br />MCC Response: Text was added to include a discussion of AVFs. <br />4.05.13 Surface and Groundwater Monitoring <br />117. Please add to the PAP a discussion of points of compliance for groundwater monitoring, as <br />found in Rule 4.05.13(b). This would include discussion of baseline groundwater quality, <br />groundwater quality after mining, potential and observed impacts to groundwater quality and <br />the potential for migration of any impacted water off the permit area. This could be done in <br />• conjunction with the discussion on page 2.05-222 of the PAP, dealing with "protection of <br />hydrologic balance." <br />MCC Response: Text was added to 2.05 of the PAP addressing the groundwater <br />protection. <br />118. Regarding discussions among MCC, personnel from the State Engineer's Office, and the <br />Division, MCC must ensure that all monitoring devices, including flumes for measuring <br />surface water flow, are installed, maintained, and working properly. Please provide comments <br />to address the issue that was raised by the SEO personnel. <br />MCC Response: MCC addresses the flumes upstream and downstream in the text. MCC <br />understands the rules and the need for maintenance, however, there are others who <br />control access and may not recognize MCCs need for the data. <br />119. On page 2.04-51, proposed text states "Table S has been updated...and new monitoring <br />wells have been installed in SOD. A separate TR will be submitted to address the associated <br />changes in the hydrologic monitoring program." It would not be appropriate to approve SOD <br />without an acceptable hydrologic monitoring plan. Please incorporate a hydrologic monitoring <br />plan for SOD in PR-10. The plan should include details on the surface water monitoring plan, <br />describing how losses of flow in the Dry Fork of Minnesota Creek will be identified and <br />reported (as per Exhibit 52). <br />• <br />