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<br />-3- <br />2. The surface water monitoriny sites on Lick-Creek, South Prong, <br />and Horse Creak will be used in future permits to ;neasure the <br />effects of mine depletions on the surface water regime. Ho~.vever, <br />since the sites are located upstraain near the center of the lease <br />area tney will not be sensitive to any depletions incurred <br />downstream by the mine. Tie current sites would therefore, may <br />bias the results. In order to fully assess the total amount of <br />depletions on the streams, the sites should be relocated downstream <br />below the affected areas. The operator is encouraged to consider <br />this and respond if appropriate. <br />3. Surface .voter monitoriny in Dry Fork occurs at Lower Dry Fork <br />(below the lease area) and in two places on Upper Dry Fork. Tnis <br />monitoring network is geared to identify surface water depletions <br />through well depth measurements, spring flows, and mine inflows all <br />of which might be considered from one viewpoint to be secondary <br />measurements. A direct measurement of stream flow reduction would <br />be difficult using the Lower Dry Fork gage since it is affected by <br />controlled releases from Minnesota Reservoir. Amore appropriate <br />site to measure surface water depletions inignt be to locate a gage <br />at the inlet to Minnesota Reservoir. Tnis site would not be <br />influenced by diversions for water user. The operator is <br />encouraged to consider this and respond if appropriate. <br />4. A review of the current Mt. Gunnison ~4ine plan indicates that <br />the subsidence test panel will be the only panel to be retreat <br />mined during the first five year per,nit term. This panel is not. <br />proposed to be mined until the fifth year of the permit term. The <br />original permit approval ooserved that the Division considered it <br />extremely important that subsidence-related geotecnnical and <br />hydrogeological data be collected, in order to facilitate the <br />consideration of future mining permit application plans at the ~•1t. <br />Gunnison No. 1 Mine. Mining of the test panel during the final <br />year of the initial permit term will probaoly not provide <br />sufficient data regarding the mechanical and Hydrological impacts <br />of subsidence to allow the Division to complete formulation of the <br />necessary findings regarding any areas of future proposed mine <br />plans which are hydrologically adjacent to the Dry Fork drainage. <br />Mt. Gunnison should consider relocating the test panel so as to <br />obtain data earlier in the permit term. Such a relocation would <br />require revisiny the :nine plan and prooably the permit boundary <br />through an appropriate revision. <br />