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<br />the operator to provide studies which have been done on <br />natural subsidence crack healing. <br />6. The consultant states that the drainages are strongly <br />influenced by fractures, and that only in areas where <br />fractures exist in drainages under low cover would there <br />be a risk of subsidence causing intercommunication of <br />water with the mine workings. Zf this is true, how was <br />the conclusion reached that the probability of impact to <br />surface streams is low? (p. 2.05-137) <br />7. The operator has correctly stated that rockfall due to <br />subsidence is possible and would be a hazard to people. <br />So would large, deep cracks in the earth, especially <br />along roads. How will these hazards be identified and <br />addressed? <br />Rule 2.05.6 Protection of the Hydroloaic Balance <br />1. Hardness should be added to the water quality parameter <br />list for both surface and groundwater. <br />2. Why does the table on p. 2.04-81 to 83 indicate "current <br />permit area" and " Apache Rocks". Shouldn't the page <br />read assuming approval and therefore, not differentiate? <br />3. Pond designs for pond MR-2A do not included a baseflow <br />for mine water discharge.. Also, review of this pond <br />design shows that this pond is not a gate controlled <br />structure (i.e. water can enter the top of the riser and <br />exit at all times) Text verbiage seems to indicate all <br />West Elk ponds are containment designs, which is <br />incorrect. <br />4. Pond MB-1 needs a water level indicator installed at the <br />1.86 acre-ft level below the emergency spillway. <br />5. Pond MB-3 needs a water level indicator installed at the <br />6063 foot elevation of the pond. <br />6. The wellhead elevations for SOM-128-H and well SOM-129-H <br />are incorrect based on logs and the top of the B-seam. <br />Again, well elevation and completion information should <br />be confirmed as accurate for all water wells prior to <br />accepting the proposed monitoring plan. <br />7. The operator should address why the EC recorded on well <br />SOM-128-H does not appear to correlate to TDS values. <br />(1120 umhos/cm EC vs. 8200 mg/1 TDB) <br />8. Wells SOM-45-H1 and SOM-45-H2 are completed in the same <br />formation right next to each other. What is the purpose <br />of the somewhat redundant monitoring? <br />