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PERMFILE47013
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PERMFILE47013
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Entry Properties
Last modified
8/24/2016 10:49:05 PM
Creation date
11/20/2007 1:00:21 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2006073
IBM Index Class Name
Permit File
Doc Date
4/4/2007
Doc Name
Adequacy Response 2
From
Banks and Gesso, LLC
To
DRMS
Media Type
D
Archive
No
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Sundance Resource, M-2006-073 <br />Second Adequacy Response <br />April 3, 2007 <br />Page 3 <br />Rule 6.4.7 -Exhibit G <br />Rule 6.4.7, defining Exhibit G, states the requirements for a study provided by <br />the applicant, detailing water-related information. One component of the study is <br />a characterization of the aquifer, if any, lying under the affected area. This <br />Exhibit G includes an attached study by Martin and Wood Water Consultants, <br />concerning the Fountain Creek alluvial aquifer and effects of mining on <br />groundwater in the vicinity. <br />The Martin and Wood study includes discussion of depletions during mining, <br />dewatering operations, slurry walls, a recharge trench, and other mitigation <br />principles to be applied to the site. As modeled for the study, the drawdown <br />potential of dewatering is significant in a few specific years of operation. <br />However, the Sundance property is large, and many of the significant effects are <br />contained before they adversely impact the protected interests of any <br />surrounding property. <br />The Division has recently contended that regulation of hydrologic balance <br />includes the protection of trees in the vicinity of mining. Trees on the property of <br />the applicant are the property of the applicant. The hydrologic balance cannot be <br />accurately measured using tree mortality as an indicator. There are many <br />causes of forest collapse and succession, and the objective of the plan for the <br />property is to restore the site to its natural and economic functions. The <br />reclamation plan as previously submitted includes new trees, and the applicant <br />has, in addition. to measures identified in the Ground Water Monitoring and <br />Mitigation Plan (see below), added a note to Exhibit F, the Revised Reclamation <br />Plan, providing: "Tree Replacement. At the time of final reclamation, or sooner, <br />but not to occur prior to the cessation of dewatering operations, the operator shall <br />plant replacements at a minimum 1:1 replacement ratio in quantity, at the <br />discretion of the Division of Reclamation, Mining, and Safety, in the place of any <br />healthy canopy tree that is stressed by dewatering to the point of irreparable <br />damage." <br />In most cases, as emphasized in the Ground Water Monitoring and Mitigation <br />Plan, mitigation of impacts (e.g., techniques such as irrigation, limitations on <br />dewatering, hydraulic structures) will be possible, making drastic measures to <br />preserve the applicant's own property unnecessary. <br />Corrective measures, to be taken in the event of hydrologic impacts on some <br />regulated interest, are specifically defined in the attached Ground Water <br />Monitoring and Mitigation Plan. <br />Rule 6.4.19 -Exhibit S <br />This Rule has been addressed with the mailing of an Agreement for <br />Compensation by Mining Operations to all owners of structures within 200 feet of <br />
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