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The effect of releasing sediment-deficient waters from the sediment ponds <br />should be minimal. Any downcutting should be limited to the point of <br />discharge and immediately downstream. The gradient from the sediment pond is <br />relatively flat, thus erosive velocities should not be attained. <br />A technical assessment of the effects of undermining Rapid and Cottonwood <br />Creeks was completed by the Division. The analysis shows that in the absence <br />of subsidence or flow through natural fractures changes in flow would be <br />insignificant, and there would be no material damage to downstream users. The <br />applicant will be mining beneath the stream valleys according to a limited <br />extraction plan. Therefore, possible subsidence effects should be avoided. <br />The possibility of flow through natural fractures is difficult to predict. <br />Major fractures Such as a fault would normally be identified during resource <br />evaluation, and none has been identified by the applicant. Minor fracture <br />(jointing) is ubiquitous in sedimentary rocks. However, joints may be open or <br />closed to the passage of water. Their effect cannot be accurately predicted, <br />but can be monitored. It is therefore appropriate to monitor the <br />stream-alluvial aquifer system during mining and reclamation, and to identify <br />the appropriate mitigations that would be undertaken should monitoring <br />identify an undesired effect. <br />Presently, there are three surface water monitoring stations located on Rapid <br />and Cottonwood Creeks. One is located downstream from the permit area below <br />the confluence of the two drainages. The remaining two are situated upstream <br />from the 5 year term permit area, one on Rapid Creek and the other on <br />Cottonwood Creek. The measuring devices are sized to show seasonal flow <br />variations and provide accurate measurements during low flow periods. The <br />gauging stations are equipped with continuous recorders, and data is gathered <br />quarterly and submitted to the Division on an annual basis. <br />As previously stated, in the absence of subsidence, there should be no <br />significant effect on the flow in Rapid Creek and Cottonwood Creek. However, <br />in the unlikely event that surface flows were depleted through natural <br />fractures or subsidence related fractures, the applicant would be required to <br />mitigate the effects from mining. To facilitate this, the applicant has <br />supplied a contingency plan which describes the measures that will be <br />undertaken to provide water to downstream users in the case that the surface <br />and ground water monitoring indicate that the mining operation is having an <br />adverse effect upon those users. <br />In addition, if the proposed mining operation does deplete the flow in Rapid <br />Creek and Cottonwood Creek, the water in the alluvial aquifer would also be <br />depleted. This would not be immediately discernable from surface water <br />monitoring or from inflow monitoring in the mine. Therefore, in order to <br />provide an indication as to whether any increased mine inflows were due to <br />depleting a perched aquifer or were due to depletion of alluvial ground water," <br />the applicant has installed a monitoring well system within the alluvium of <br />Rapid and Cottonwood Creeks. The system consists of two wells each in the <br />Cottonwood and Rapid Creek alluvium directly over the mine workings. At each <br />location, the wells have been completed to bedrock. One well at each location <br />contains perforated casing throughout its entire length and the second well at <br />each location contains perforated casing only in the lower most portion of the <br />alluvium. <br />-19- <br />