REV14895 - Laserfiche WebLink

Home Browse Search

The monitoring plan needs to be determined exactly and incorporated in the permit text. Baseline data should be presented for each well in the plan and should be included as part of the permit. Regardless of what data was available at the time the permit application was initially approved, this is a valid issue to raise during the mid-term review process. It only makes sense that everyone is clear on exactly what are the requirements of the hydrologic monitoring plan to avoid confusion and problems in the future. b. Surface water rnfonnaion for Carbon Junction Carryon is minimal as far as ephemeral flow information. Apparently this carryon generally flows only in response to precipitation events anal to some degree snowmek in the spring. As will 6e apparent in my comments for the following Rule, the magnitude of the occasional surface water runoff event is of considerable importance as far as stability of the fill which currently occupies the Carbon function drainage channel Rule 204.7(2)(b)(i) requires minimum, maximum, and average flow information, which is lacking in the currently approved permit. Response accepted. Rule 205.6(3) Protection of the Hydrologic Balance a This section is very weak with regard to surface water given the present configuration of the mine. Little to no discussion is presemed with regard to impacts to surface water quantity and quality, even though the permit text states, 'The Carbon Junction Mine will rmpact both the quality and quantity of ground and surface waters" (p. 5-40). Page 5-41 states that "Surface water outside of the disturbed area is diverted, as much as possible, into adjacent drainages which flow to the Animas River." However, discussions with you and review of the aerial photos indicate flows from Carbon function Carryon are impounded by the fill placed directly into the carryon and its corresponding channel It is also not clear whether the East and West Collection Ditches are appropriately installed or furthermore, whether they exist at all in some places. Clearly, the hydrologic balance is being affected within the permit area and to some degree outside of the permit area due ro this practice. Response accepted. b. The permit text presents the monitoring plan responses under the wrong Rule heading. Rule 205.6(3)(b)(iii) should present the probable hydrologic consequences of mining to surface and ground waters in the permit and adjacent area Presently this section basically ignores marry of the probable hydrologic consequences to surface water. The response to Rule 205.6(3)(b)(iv) in the text (which is labeled (e)(b)(iv)) is also incorrect, as it speaks to the recharge capacity rather than presenting the hydrologic monitoring plan. Additionally, the hydrologic monitoring plan is not clearly presented and apparently lacks arty monitoring of Carbon Junction Carryon. Due to the apparent confusion, I would suggest that the operator re-work this entire section, correcting and beefuzg up the text as necessary.