REP10679

• Permit No: C1982057
• IBM Index Class Name: Report
• Doc Date: 2/3/2004
• Doc Name: 2002 & 2003 AHR Review Memo
• From: Dan Mathews
• To: Sandy Brown, Mike Boulay
• Annual Report Year: 2002
• Permit Index Doc Type: Hydrology Report
• Media Type: D
• Archive: No

WW4 abandoned August 2003, "will be replaced in 2004". Ditto far WWC4.
I believe we need to request that the operator submit a technical revision addressing
replacement well locations, specifications, deadlines, etc.
PR-3 was approved in June 2003, and the II-W PHC impact projections were
adjusted to incorporate the mine plan changes, including mining of the Wedge and
Wolf Creek seams. The AHR report this year continues to base TDS impact
comparisons in the report narrative on pre-PR-3 TDS projections. This is probably
not a significant issue, since mine plan changes were not implemented until the 3rd
quarter 2003, which is the last quarter of the water year covered in the AHR. It
may be appropriate to remihd the operator that next year's report narrative should
reflect the current PHC projections. There was no narrative comparison of TDS
projection vs. observed for Surface Water Site WSH7, on upper Hubberson Gulch,
This would seem to be a significant oversight, due to the AVF irrigated pastures that
are irrigated with this water. The AHR narrative should be amended to address
projected and observed average irrigation season TDS value for this site,
Comments on PHC Section of Permit; Dry Creek AVF Material Damage Projections
In the course of reviewing the AHR, I took a pretty close look at certain sections of the PHC
in Tab 17 of the PAP. I noted conflicting information and certain apparently erroneous
assumptions regarding TDS based material damage projections pertinent to subirrigated
fields on Dry Creek. Based on my initial review, it appears that an erroneously low TDS .
value may have been used to predict crop yield reductions, and that assumptions regarding
crop response to salinity may. also have underestimated yield reductions:
On page 53, there is the following statement:
Though the duration of the high TDS spoil flow into Dry Creek streamflow will be
/ong-term and the magnitude of the increases compared to background levels is
high, no downstream water uses will be injured. The two farmed fields above J.C.
Temp/e Reservoir #2 (see Exhibit 16-3, .Section 9J are subirrigated and wi// not be
affected by surface f/ow in Dry Creek. (Emphasis mine). The conclusion regarding
the lack of connection between Dry Creek surface water quality and alluvial water
quality does not seem to be well supported, and subsequent sections of the permit
make the assumption that there is a connection between surface water quality and
alluvial water quality. The operator will need to amend this narrative to conform
with subsequent sections of the permit, or the. statement will need to be adequately
documented, and subsequent sections of the permit will need to be correspondingly
amended.
On pages 126 through 128, there is a very thorough and well documented AVF field crop
study and associated evaluation of the impact of projected irrigation water salinity increase
on the productivity of AVF hayfields on Hubberson Gulch (Smith Ranch Fields). The
evaluation includes Table 77-43a (Smith Fields species composition) and Table 17-43b
(Smith Ranch Fields Crop Yield Production Projectidns). The crop study and associated
material damage evaluation were apparently conducted in 2001, and represent the most
recent, and most thoroughly documented crop salinity impact evaluation conducted in
association with the Seneca it-W permit. I reference this evaluation in order to contrast the .