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Exhibit 20. <br />5. Please update page 2.05.6-1 to be consistent with the current air emissions permits and stockpile <br />volumes. <br />6. The Division's copies of the permit application are missing one copy of Map 9. Please provide <br />an additional copy of the currently approved map. <br />7. As discussed in a recent site inspection, DMG would prefer submittal of an annual hydrology <br />report which is based on an October 1 through September 30 water year, with the report being <br />submitted to the Division on or before February I of each yeaz. <br />8. The text on page 3.0-2R does not logically follow that of page 3.0-1R. Please revise the pages <br />as necessary for continuity. <br />9. The permit application identifies Oak Creek as an alluvial valley floor. EFCI currently monitors <br />one surface water site on Oak Creek, downstream of the loadout azea. DMG is concerned that <br />data gathered under this monitoring program will not be sufficient to determine whether there <br />have been any mine related impacts to the alluvial valley floor. We highly recommend EFCI <br />propose an upstream site and monitor upstream and downstream simultaneously do more <br />accurately define any mine related impacts. <br />10. EFCI does not currently monitor groundwater in the loadout area. There is conflicting <br />information provided in the permit document pertaining to the need for monitoring in the <br />loadout area. On what basis was groundwater monitoring not proposed? <br />11. The hydrologic monitoring program currently includes a number of surface water sites which <br />are downstream of the disturbance and/or azea, but there aze not corresponding upstream sites <br />for them. It would be in EFCI's best interest to add upstream sites for each site, so that any <br />possible degradation of water upstream of the mine can be differentiated from mining related <br />impacts. <br />12. It is not clear from [he monitoring plan presented in Exhibit 25 whether monitoring wells aze <br />purged prior to sampling. Please provide details of EFCI's sampling protocol. <br />13. The groundwater information section of the permit application package does not currently <br />include well construction details, such as ground surface elevation, measuring point elevation, <br />well depths, screen interval, and the formation in which each well is completed. Please include <br />groundwater monitoring well construction details in Section 2.04.7 of the permit application <br />package. <br />14. Page 4.05-2R states that the Magpie Creek diversion is temporary and will be removed. Please <br />update the text to reflect that the diversion has been approved as a permanent diversion. <br />15. Please provide current CDPS permits to replace the expired permits currently in the permit <br />application package. <br />Southfield Mine (C-81-0301 April 18, 1997 <br />Midterm Revicw ~] Third Permit Tcrm <br />