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;. <br />~I I ~ II I I~ I I~ ~~~~ II~ <br />DIVISION OF MINERALS AND GEOLOGY <br />Dep.rnmCnl nl Ndlura Resources <br />117 S Shcrmun $L. Room ?1 5 <br />Dr,nacr, Colorado HO'_03 <br />Phurn•: I NIL Hfi6~1567 <br />F:\X. 1 4U it N }bHl OG <br />Date:November ], 1998 <br />To: Berhan Keffelew <br />STATE OF COLORADO <br />~' ~ -'(- V 1/ V <br />~u <br />~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Rn7 Rrnner <br />Gurenmr <br />lames S Loc hhead <br />E~ew~i~e Director <br />MrchaelB LnnR <br />Drvrsion Urrecmr <br />From: Jim Stevens JLG/ <br />RE: Review of CC&V response to Amendment 7 ground water adequacy issues <br />As a result of my review, I have the following comments: <br />1. Map (CC&V response 25): A revised water monitoring map and supplementary maps <br />have been supplied, appazently in order to meet the requirements of Rules 6.4.7 (2), 6.4.20 (8) <br />(a), 3.1.7 (7) and 6.2.1 (2) but this adequacy issue has no[ been fully addressed. <br />a) The HCI map supplied to supplement Figure 5 and intended to show the locations of <br />the tunnels does not meet the requirements of Rule 6.2.1 (2), 6.4.7 (2) or 6.4.20 (8) and cannot be <br />accepted. The map itself does not represent acknowledgement by the applicant that discharges <br />from the drainage tunnels may be impacted by the operation.The map does not show the name of <br />the applicant nor is it identified as part of the current application (as is Figure Sa). It has no land <br />survey grid indicating CC&V takes any responsibility for its accuracy. <br />Figure 5 should be further revised to show the tunnel locations. It would also be useful if <br />the outline of the diatreme was indicated on Figure 5 in order to allow cleazer identification of <br />the various aquifers the tunnels and monitoring wells represent. <br />b) Although clearly improved, the revised Figure 5 does not, at this time, contain all the <br />information required by Rules 6.4.7 (2) and 6.4.20 (8) (a) and cannot be accepted for such <br />purposes. It does not show (nor has it been properly supplemented to show) the locations of the <br />underlying tunnels whose discharges the operation has the potential to affect. It also lacks the <br />locations of certain wells such as WCMW-5 and WCMW-3 together with monitoring wells on <br />record with the SEO in Sections 16, 17 and 18 which not only lie within the proposed DMO but <br />near enough to elements of the operation that the ground water these wells monitor may be <br />impacted. In regard to satisfying the requirements of 3.1.7 (7), the map does not contain the <br />locations of all features, ie. the tunnels, and wells the Division believes should be included in the <br />monitoring plan (See discussion of the Groundwater Monitoring Plan ). <br />