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<br />-4- <br />b. A letCer from the. state uigineer's Office (SEO) and pond design <br />summaries found on pages 3-6ua and 5-67 .vould indicate Chat ponds are in <br />excess of 10 ft. and therefore meet SEO criteria. If this is the case, <br />the operator shall submit proof of compliance with any examination <br />requirements of the State Engineer in accordance with Rule 4.U 5.6(11)(a). <br />c. Tne :monitoring section of the application should include a <br />discussion of the devices used to monitor all water intake and discharge <br />at the mine. Sources such as raw ••voter intake, mine discharye, <br />sedi;nentation ponds and fresh rioter ponds should be addressed. <br />d. The drainage and sediment control system is designed to effectively <br />collect and treat all disturbed drainage from the mine site prior to <br />discharge. This system is required under Rula d.Oti to be retained until <br />the site is reclaimed, reveyetated, and the runoff exhibits quality <br />equal or wetter than natural runoff. Although this system functions <br />properly at this tune, it :nay not function properly during reclamation. <br />This is because reclamation will involve the removal of roads (including <br />roadside ditches), berms, culverts, buried conduit, manholes, etc. <br />During this reclamation phase runoff may not drain to the ponds because <br />of the backfilling, grading, demolition, and removal of drainage <br />structures taking place. Therefore, tot. Gunnison is required to design <br />a revised reclamation and drainage control plan that addresses in detail <br />the timing and sequence of reclamation and how the drainage and sediment <br />control system will remain functional throughout the reclamation period. <br />In addition, given the fact that sediment ponds are a significant <br />percentage of the surface disturbance at the mine. The operator should <br />submit a detailed plan for alternative sediment control to minimize <br />erosion and siltation once sediment ponds are removed and the area <br />reclaimed. <br />3. Climatological Information <br />a. It is our understanding that the '.Jilcox Range rain gage has peen <br />replaced. Page 2-53 (Precipitation Discussion) should be revised to <br />reflect the current status of rain gages to be used by the mine. This <br />information is important for determining whether local rainfall data <br />oeing collected is characteristic of the mine site. <br />4. Topsoil <br />a. A topsoil stockpile inventory conducted by the operator revealed <br />that they may be 9,500 cubic yards short of material. This may have <br />been due to settling, compaction, or miscounting scraper loads of <br />material. It is possiole that excess material may be salvaged in the <br />future from the permanent waste rock site. Ho~.vever, at this tune, the <br />material is not available and the upper waste rock site is not a <br />permitted activity. Therefore, the bond amount will need to include the <br />costs of salvaging and transporting this material from the upper waste <br />rock site. (See fionding Section.) <br />