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water standazds and is done through the Commission rulemaking and public hearing process. <br />Our Division cannot assign classifications and standards to specified areas of groundwater nor do <br />we have the regulatory authority to grant variances or apply "alternative compliance points". <br />3. Significant discussion is given to justification for an "alternative compliance point", but <br />the report didn't provide for an alternative point of compliance and it is unclear if a point of <br />compliance would be established for those perched water zones above 300 feet. No point of <br />compliance is recommended or established with this report for any of the aquifers or water <br />beazing zones that have been reviewed in previous permitting efforts or Findings by the Division. <br />4. In the conclusions and recommendations section 5 it is stated that "aquifers within the <br />Mine permit boundary and those down gradient from the Mine aze not used for domestic or <br />agricultural uses"... and "these aquifers do not have a classification to support existing or future <br />uses..." Classification of State Waters is the sole responsibility of the WQCC. Until such time <br />that the ground water is classified, the applicable and relevant standazds aze the Interim Narrative <br />standazds (INS) in Reg. 41. For the Bowie No. 2 Mine the standazds that apply are the least <br />restrictive of either: <br />1) existing ambient quality as of January 31, 1994,or <br />2) the most stringent criteria from Table 1 through 4. <br />The INS would be in effect until such time that ground water is classified by the WQCC or our <br />Division has sufficient documentation to determine that the site does not have the potentia! to <br />negatively impact the quality of ground water for which quality standards have been established <br />by the WQCC. <br />5. There was good information presented in the report [hat may assist in making a judgment <br />regarding the potential for the operation to negatively impact groundwater. The Division <br />recommends that the information presented in the report be incorporated into the PAP through a <br />revision application to expand upon previous Findings regarding the potential impacts to the <br />Upper and Lower Perched Water Zones and the Rollins sandstone. There is already discussion in <br />the Probable Hydrologic Consequences (PHC) regazding the fact that confining shale layers and <br />piezometric head should prevent any integration of water from either the D-Seam or B-Seam into <br />the Rollins sandstone. The approach presented in the report focused in general terms on all <br />groundwater greater than 300 feet with minimal discussion of the Rollins sandstone and no <br />mention of the Upper and Lower Perched Water Zones that has been reseazched and documented <br />in the PAP. In recent years a primary focus of our groundwater reviews has been whether a point <br />of compliance should be established in the Rollins sandstone (a recognized aquifer in the area) as <br />mining progresses to the north and to the west towards Terror Creek. There was no additional <br />water quality data or any comparisons to baseline information presented to support a <br />determination of no potential for impact to bedrock ground water. [t is recognized that bedrock <br />groundwater formations in the vicinity of the mine have low transmissivities. However, with <br />regard to the movement of ground water there was no new information or data presented. There <br />was no additional information presented with regazd to the potential effects from faulting and <br />fracturing at depth. Table 1 summazizing water yield from the underground operation was <br />2 <br />