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Kiowa Clay Mine, M-2007-009 <br />Response to Adequacy Comments <br />17 April 2007 <br />Page 10 <br />suggestion of streams or floodplains with a connection to groundwater. The lack <br />of groundwater impacts is demonstrated in the Response to Comment 16, below. <br />Impacts to surface water are also a nominal possibility, but not likely due to the <br />topography of the landscape. Because the proposed site is on a ridge, there will <br />be no concentrated flows of water and no conveyance of off-site water moving <br />through the site. There will be no watercourses intercepted, no bodies of water <br />within the affected area, and no affected irrigation facilities or other water rights. <br />There is currently a private stock pond on the property, but this is outside the <br />affected acreage. No new stock ponds or bodies of water will be manually or <br />naturally created on the affected acreage. <br />To account for the potential surface disturbance, the operator will mitigate water <br />quality impacts with a sedimentation facility. Additional information and details <br />will be included in a stormwater management plan, as required by regulations <br />outside the Reclamation Permit process. <br />16. The applicant will need to supply the Division with proof of the <br />seasonal high groundwater elevation. The applicanf will need fo submif <br />this data to the Division during the review period for this application or in <br />the form of a revision to the permit prior to the commencement of mining <br />as stated in the application. In addition, the applicant should stay 5 feet <br />above the seasonal high groundwater elevation unless it can be <br />demonstrated the mining will not intercept groundwater at a lesser depth. <br />Well records were collected from the State Engineers Office for wells on the <br />affected acreage and in surrounding townships. This data represents the average <br />seasonal high groundwater elevation. The average groundwater depth for 12 <br />surrounding wells is 289 feet. The average groundwater depth for the 3 wells in <br />Township 19 (location of affected acreage) is 300 feet. The site will be mined to a <br />depth of 60 feet, providing approximately 240 feet of material in between mining <br />operations and groundwater levels. It is reasonable to infer that no impacts to <br />groundwater will occur as a result of the proposed operation. <br />The applicant also reiterates its commitment to comply with state law concerning <br />water impacts. Should groundwater be encountered during mining, the operator <br />will either backfill at least two feet above any intercepted groundwater or amend <br />this Reclamation Permit to account for groundwater impacts. <br />17. Please provide DRMS with a copy of the Storm Water Management <br />Plan (SWMP) and the Spilt Prevention Contro! and Countermeasure <br />(SPCC) Plan the operator submitted to the Water Quality Control Division. <br />Please make any changes necessary to maps to specify where ditches <br />