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I~ <br />U <br />I. <br />Doc Date:12/11/2001 <br />III IIIIIIIIIIIII III <br />sss <br />5 /E : MLRD - Preliminary Adequacy Review - Edna Mine <br />Hvdroloov Description - 2.04.7 <br />A. Pittsburg and Midway should submit for inclusion into the permit a <br />detailed description of both ground and surface water sampling and <br />monitoring techniques (discharge, water levels, water quality), and <br />preservation methods for samples sent to the laboratory. <br />P&M BELIEVES THE INFORMATION REQUESTED HAS ALREADY BEEN PROVIDED IN <br />THE PERMIT, EXCEPT FOR "MONITORING TECHNIQUES AND PRESERVATION <br />METHODS" WHICH ARE ENCLOSED. THIS INFORMATION MAY BE DIRECTLY <br />INSERTED INTO THE PERMIT AS PAGE 4.6-140a. THE REMAINING <br />INFORMATION MAY BE FOUND IN SECTION 4.6, PAGES 4.6-139 THROUGH <br />4.6-141A. <br />• <br />B. The operator should submit a detailed plan for monitoring the <br />development of a spoils aquifer in the backfilled Moffat mining <br />area. This plan should include, but not be limited to the <br />monitoring of water wells completed in the spoils, and spring and <br />seep surveys which should include discharge measurements as well as <br />water quality sampling. <br />A GENERAL PLAN FOR MONITORING THE POTENTIAL SPOILS AQUIFER IN THE <br />MOFFAT AREA I5 ENCLOSED AND MAY BE PLACED DIRECTLY INTO THE PERMIT <br />AS PAGES 4.6-140a AND 4.6-140b. HOWEVER, IT WILL NOT BE POSSIBLE <br />TD SUBMIT A DETAILED MONITORING PLAN AT THIS TIME. A DETAILED PLAN <br />CAN BE SUBMITTED ONLY AFTER THE MOFFAT AREA STABILITY STUDY <br />REQUESTED BY MLRD IS COMPLETED AS THE STUDY MAY REQUIRE <br />MODIFICATION TO THE PROPOSED MINE PLAN. <br />C. The Division requests that the annual spring and seep survey be <br />modified as follows: <br />Reclaimed portions of the Edna Mine will be walked <br />twice per year, once in early to mid June and once in <br />early to mid October. All springs and seeps will be <br />mapped and discharge data collected. All springs <br />which flow more than 3 gallons per minute will be <br />sampled for field parameters (temperature, pH, <br />specific conductance). These maps and the data <br />collected will be submitted as part of the annual <br />hydrologic report discussed in item E.) below. <br />THE SPRING AND SEEP SURVEY WILL BE INCLUDED IN THE ANNUAL <br />HYDROLOGIOC REPORT. NO CHANGE IN THE PERMIT TEXT IS REQUIRED BY <br />THIS COMMENT. <br /> <br />D. The Division has reviewed the Probable Hydrologic Consequences <br />(PHC) and Cumulative Hydrologic Impact Statements (CHIS) contained <br />in the original permit document submitted in 1980 and feels that <br />Pittsburg and Midway should revise and update these statements as <br />