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9 <br />13. Page 2.04.7-91, In its discussion of potential impacts from mining to the groundwater <br />quality, Colowyo does not discuss Total Dissolved Solids (TDS). What are Colowyo's <br />predictions of impacts to groundwater quality with respect to TDS? <br />14. Pages 2.04.7-3 and 2.04.7 references springs and seeps in the permit area. There <br />appears to be no language regarding the springs and seeps located in the West Pit <br />area or the constructed lateral drain. Rule 2.04.7(1)(iv) states that the application <br />shall contain a description of the ground water hydrology including springs. Please <br />inform the Division as to how Colowyo plans to verify that the West Pit Mining <br />operations will have any impact to springs or seeps in Taylor Creek. Please also <br />update the portion of the permit to make note of the springs at the West Pit and a <br />map locating the springs and constructed drains per Rule 2.04.7(4)(d). <br />15. Reference is made in the permit application to "cascading waters" and numerous <br />springs and seeps (apparently of limited duration), yet Colowyo does not conduct an <br />annual spring and seep survey. Based on the information in the permit, the Division <br />recommends that an annual spring and seep survey be conducted at the Colowyo <br />mine. <br />16. Colowyo depicts the topsoil balance and schedule in bank cubic yards (bcy) as <br />opposed to loose cubic yards (Icy). Please inform the Division how Colowyo <br />estimates the swell factor into the topsoil numbers and replacement depths. <br />17. On Page 32 of the June 4, 1992 (Revised: July 23, 1992) Findings Document, it is <br />stated that total canopy cover would be evaluated for determination of revegetation <br />success. This conflicts with the narrative in Section 4.15.8 of the permit application <br />which indicates that herbaceous cover, rather than total canopy cover would he the <br />pertinent success criterion. <br />a. Is the standard as set forth in the findings document in error, was the standard <br />modified through an approved revision subsequent to issuance of the findings <br />document, or is there some other explanation for the discrepancy? <br />b. Tables 2, 2A, and 3, in the permit application present herbaceous cover data for <br />1980 and 1988 sagebrush and mountain shrub pre-mine sample areas. Assuming that <br />total canopy cover was sampled in the original baseline data collection efforts, how <br />was the data adjusted to reflect only herbaceous cover, litter, and bare ground, with <br />woody plant data absent? Was multiple hit cover data employed, such that first hits <br />on woody plants were replaced by second hit data on herbaceous cover, litter, or bare <br />ground, or were hits on woody vegetation by convention reclassified as litter, when <br />the revision from total cover to herbaceous cover was made? The sampling <br />description in Section 2.04.10 of the application should be amended to clarify this <br />matter. <br />