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<br />In order to fully satisfy the requirements of Rules 6.4.7 (2), 6.4.20 (8) (a) and 3. l.7 (7), <br />Figure 5 should be further revised to include locations of the various tunnels underlying the <br />DMO, CC&V monitoring wells WCMW 5 and 3 and those monitoring wells located in SW <br />Section ]6, NW and SW Section 17 and SE Section 18. If, however, no groundwater was <br />encountered by the monitoring wells in SW Section 16, NW and SW Section 17 and SE Section <br />l8, a cleaz statement to that effect will suffice to justify excluding them from the map. <br />HYDROGEOLOGY (CC&V response 26): The applicant has made a lengthy <br />argument that the application and included reports fully meet the requirements of Rule 6.4.20 (8) <br />(e) for the proposed operation. The Division cannot completely agree at this time. Based on the <br />indicated quality and depths reported for groundwater in Section 17 (North part of Grassy Valley) <br />and in the NW Section 20 (across the topo divide from the proposed East Cresson Mine), there <br />appeazs to be useful water of unknown extent consistently available at reasonable depths in these <br />areas. Although these groundwater occurrences have been termed "perched" in the application <br />and in the consultant's reports and, by implication, are limited in extent, some of this <br />groundwater may be located outside the limits of the diatreme and not subject to the drainage <br />effects of the tunnels. Some of this groundwater, although within the area of the diatreme, may <br />represent significant occurrences of groundwater simply isolated from the influence of the <br />tunnels. At this point, no tangible evidence, historic or otherwise, in the form of water depths in <br />mines and wells from these areas has been supplied to demonstrate that a deeper "district wide" <br />water table actually underlies these aeeas of useful ground water, that the bulk of the groundwater <br />in these aeeas is "essentially"(as claimed) under the control of the tunnels and that the extent of <br />this groundwater is neglible. <br />Either tangible data on the depth of a "district wide" water table underlying the aeeas of <br />shallow useful water in Sections 17, 18 (?) and 20 should be supplied to establish that the <br />hydrogeology of the entire DMO has been adequately described in the application and by the <br />third-party consultant's reports or the hydrogeology of those areas of useful groundwater quality <br />in the northern portion of the DMO, inside and outside of the diatreme and appazently isolated <br />from the drainage effects of the tunnels, should be investigated more fully and described. <br />GROUNDWATER USES (CC&V response 27): The applicant's statement that there is <br />no existing use and no reasonably potential use of ground water on and within two miles down- <br />gradient ofthe proposed DMO is unacceptable, based on available records. The Division's <br />limited check of the records of the SEO shows wells listed as having "household use" in SE and <br />SW Section 31, clearly within two miles and "downgradient" from the proposed DMO. <br />The applicant should check the available well records and reported ground water quality <br />more cazefully and revise the application to include the information required by Rule 6.4.20 (9) <br />(a) . <br />GROUNDWATER QUALITY DATA (CC&V response 28): A minimum of 5 <br />successive calender quarters of baseline groundwater quality data has not been submitted for all <br />areas of the proposed DMO where groundwater has been found to occur. Therefore, the <br />requirements of Rule 6.4.20 (9) (b) have not entirely been met by the application. Contrary to the <br />