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PAR - C-80-007 - 11 - March 31, 1986 20. Page 23. Provide a justification for the statement...It is unlikely that any measurable injury will occur to more than one or two rights at any given time. 21. Page 24. What is the quantity (not percent) of ARCO's ownership of Turner Ditch water rights? How much water is available for ARCO's use during low flow months and during dry years? What are the priority rights on Minnesota Creek and who has senior rights and in what amount? 22. Page 25. Provide a map of Turner Ditch and Minnesota Creek showing all existing water rights and amounts in addition to ARCO's water rights. WECC needs to show that no downstream users on Minnesota Creek or Turner Ditch will be adversely affected during low flow months and during dry years. 23. Provide a list of possible impacts to all existing and anticipated stock ponds in the Minnesota Creek drainage basin and all areas of WECC's lease boundary outside of the Minnesota Creek basin. Also, provide a mitigation plan for all negative impacts. 24. Pages 10 and 11. Protection methods for the safety zone under the Dry Fork of Minnesota Creek, Horse Creek, and South Prong are unacceptable. WECC must show evidence to the Division that an adequate data base has been collected including subsidence measurements and mine inflows as requested in Stipulations 8, 15, and 22 of the Proposed Decision and Findings of Compliance for 1,630 permit revision dated August 26, 1985. Also a buffer zone adjacent to the stream needs to be defined to ensure protection of the stream banks and surrounding alluvium and should be projected downward in accordance with he angle of draw. 25. The Division requires information on projected water consumption, refuse leachate, mine water inflows, depletions to springs, seeps, and streams, and total depletions to the water balance of the affected drainage basins. Where no data is available to support your projections, worst case analysis should be used. If WECC feels that these projections might result in material damage, a plan to prevent the damage should be presented. 26. Section 2.8.5.2, Page 2-541 and 542 contains a generalized discussion of the effects of mining on springs. This discussion needs to be expanded to include a quantification of total effects to the hydrologic balance from spring depletions. In addition an attempt should be made to discuss any subsurface depletion (colluvial or bedrock) that may be affected by mining. These depletions should be discussed in relation to mean low flow and 7 day 10 year low flows of the North Fork and its tributaries. a. A discussion should also be provided on what the 1984 and 1985 monitoring data shows for springs. The application only presented data up to 1983. A narrative discussion should be included to describe any effects (if any) of undermining or subsiding any springs in the inititial permit area.