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missing from the report. Several figures were provided but there was very little information or <br />interpretation to go with the figures including no discussion on the effects that faulting may have <br />on ground water migration. Figure 5, a geologic cross section of the mine was missing from the <br />report. <br />6. The Division recommends not incorporating the R Squared Incorporated report into the <br />PAP for the reasons stated above, but also because there are implied statements regarding the <br />Division's position on ground water classification which are not entirely accurate or <br />substantiated (see section 4.4 of the report). The appropriate options for this site would include: <br />1) Implement the Interim Narrative Standards(41.5(C)(6)) from Regulation 41; 2) Through a <br />technical revision further expand upon the existing PHC discussion incorporating the information <br />contained in the referenced report and with data from the site document that there is no potential <br />to negatively impact the Rollins sandstone and the Upper and Lower Perched Water Zones; or 3) <br />Prepare sufficient information and request asite-specific classification hearing with the WQCC; <br />based on several discussions in the report ground water areas in vicinity of the mine may be a <br />candidate for proposed classification as "Limited Use and Quality" (41.4(B)(5)). <br />7. Ground water points of compliance may utilize wells approved by the Division for <br />baseline data collection or hydrologic impact assessment, or may require new monitoring <br />locations in addition to any other monitoring points required by the Division. Regardless of <br />establishing points of compliance, groundwater monitoring cannot be exempted and is required <br />throughout the monitoring liability period. This would extend until after the cessation of the use <br />of underground mine workings and until proper demonstrations are made regarding protection of <br />the hydrologic balance. <br />If you have any questions, please call me. <br />Sincerely, <br />seph J. D~sh <br />Environmental Protection Specialist <br />cc: Jim Stover P.E.(J.E. Stover & Associates) <br />c:\word\bowie2\gwpocadeq 1 <br />