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Preliminary Adequacy Issues May 4, 2007 <br />San Luis Project, AM-02 <br />Permit No. M-1988-112 Page 4 <br />10. The plans for the proposed storage ponds indicate that the ponds will be lined with a <br />compacted soil liner with a saturated hydraulic conductivity Tess than 1x10-6 centimeters per <br />second. Exhibit G.2,1 of AM-02 states that such liner will seep mine waste water at a rate of <br />52.5 acre-feet annually. The exhibit states that the base of the pond is located above the <br />surrounding alluvial aquifer. No additional information on the surrounding alluvial aquifer is <br />provided. Pursuant to Rules 3.1.5(11), 3.1.6, 3.1.7, 6.4.7, 6.4.20(8) and 6.4.20(9), AM-02 shall <br />include groundwater monitoring sufficient to adequately characterize baseline conditions for the <br />storage ponds and demonstrate how unauthorized release of pollutants to the groundwater <br />system will be prevented, and how disturbances to the prevailing hydrologic balance of the <br />affected land and of the surrounding area will be minimized for the entire period of time that the <br />storage ponds will be utilized to support mining and reclamation activities. <br />11. The 452 acres irrigation area will be used by the operation as a work area to discharge, <br />evaporate and consume the mine waste water. Pursuant to Rules 3.1.5(11), 3,1.6, 3.1.7, 6.4.7, <br />6.4.20(8) and 6.4.20(9), AM-02 shall include groundwater monitoring sufficient to adequately <br />characterize baseline conditions for the 452 acre waste discharge area and demonstrate how <br />unauthorized release of pollutants to the groundwater system will be prevented, and how <br />disturbances to the prevailing hydrologic balance of the affected land and of the surrounding <br />area will be minimized for the entire period of time that the waste discharge area will be utilized <br />to support mining and reclamation activities. <br />12. Exhibit S, Permanent Man-Made Structures, states that there are no permanent man- <br />made structures within 200 feet of the exposed highwall. However, as noted above, significant <br />acreage is being added to the permit area through the incorporation of the pipeline corridor, <br />storage ponds and waste water discharge area. Please update Exhibit S to address structures <br />within the new permitted acreage and within 200 feet of the new permit boundaries. <br />13. The application indicates that affected lands will be reclaimed to support Wildlife Habitat <br />post-mining land use. Pursuant to Rule 6.4.8(2), please ensure that AM-02 includes <br />recommendations from the Colorado Division of Wildlife. <br />14, In Exhibit E, Reclamation Plan, the application indicates that the 5 treatment ponds and <br />buildings associated with the water treatment plant shall remain as permanent structures. <br />Pursuant to Rule 3.1.11, please clarify how such structures support Wildlife Habitat post-mining <br />land use. Pursuant to Rule 6.4.5(2}(b}, please discuss alternate post-mining land uses, such as <br />General Agriculture or Industrial/Commercial, for the lands containing the water treatment <br />facility. Please ensure that AM-02 demonstrates that such permanent structures are compliant <br />with county zoning and building codes. As stated in Rule 3.1.11, the authority for approval of <br />such structures to remain as permanent resides with the Board. <br />15. In Exhibit L, Reclamation Cost, the application indicates current cost of reclamation <br />totaling $651,272. Pursuant to Rule 6.4.12, please ensure that Exhibit L addresses the cost for <br />what would be an ongoing water management program proposed in AM-02. <br />