Laserfiche WebLink
<br />Below, after some general discussion, I have outlined what I <br />have concluded after review of this section. <br />Ideally, as you know, when mining is proposed in an new area, <br />baseline data is submitted for this area to allow <br />characterization of the existing environment. Since this is <br />an expansion into areas very similar in terms of hydrology, it <br />is my opinion that for Apache Rocks, we can allow the <br />submission of data via stipulation, to be included as part of <br />the permit application. <br />a. I am satisfied with the operator's proposed locations of <br />surface and groundwater monitoring stations. The fact <br />that they have not provided baseline data for most of <br />these sites does not, in my opinion, preclude the <br />Division from evaluating the proposed expansion. <br />However, the operator should submit a time schedule for <br />collecting baseline data for each of these sites based on <br />the proposed mine plan. <br />b. All springs and ponds have apparently been identified by <br />ground survey and a time schedule would also be <br />appropriate. <br />c. The operator should not confuse operational monitoring <br />with baseline data. This is currently being done in a <br />number of ways. First, the monitoring program is <br />included in the baseline section 2.04.6 which is not <br />appropriate. The monitoring plan should be included in <br />section 2.05.6, Mitigation of the Impacts of Mining <br />Operations. Second, the operator refers the reader to <br />the Annual Hydrology Reports for baseline data. Baseline <br />data should be submitted as an Exhibit or Appendix to the <br />permit as part of section 2.04.6 for each station, even <br />those which may not ultimately be part of the monitoring <br />program. Thirdly, the operator is showing a baseline <br />minimum and maximum for each parameter. We should ensure <br />that this range is not the historic range but is truly <br />the baseline range for the one year of baseline <br />monitoring. <br />3. The text states that no clear groundwater flow direction <br />is evident. Based on the geologic and hydrologic <br />information provided by the operator, I strongly disagree <br />with this statement and recommend the operator remove <br />this statement unless they can support it with strong <br />evidence. I can elaborate with maps and data if you need <br />back-up. <br />Rule 2.05.2 Operation Plan <br />I have no questions with regard to this sections. <br />