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data presented. There was no additional information presented with regard to the <br />potential effects from faulting and fracturing at depth. Table 1 summarizing water yield <br />from the underground operation was missing from the report. Several figures were <br />provided but there was very little information or interpretation to go with the figures <br />including no discussion on the effects that faulting may have on ground water migration. <br />Figure 5, a geologic cross section of the mine was missing from the report. <br />6. I recommend not incorporating the R Squared Incorporated report into the PAP <br />for the reasons stated above, but also because there are implied statements regarding our <br />Division's position on ground water classification which are not entirely accurate or <br />substantiated (see section 4.4 of the report). The appropriate options for this site would <br />include: 1) Implement the Interim Narrative Standards(41.5(C)(6)) from Regulation 41; <br />2) Through a technical revision further expand upon the existing PHC discussion <br />incorporating the information contained in the referenced report and with data from the <br />site document that there is no potential to negatively impact the Rollins sandstone and the <br />Upper and Lower Perched Water Zones; or 3) Prepare sufficient information and request <br />a site-specific classification hearing with the WQCC; based on several discussions in the <br />report ground water areas in vicinity of the mine may be a candidate for proposed <br />classification as "Limited Use and Quality" (41.4(B)(5)). <br />7. Ground water points of compliance may utilize wells approved by the Division <br />for baseline data collection or hydrologic impact assessment, or may require new <br />monitoring locations in addition to any other monitoring points required by the Division. <br />Regardless of establishing points of compliance, groundwater monitoring cannot be <br />exempted and is required throughout the monitoring liability period. This would extend <br />until after the cessation of the use of underground mine workings and until proper <br />demonstrations are made regarding protection of the hydrologic balance. <br />Please let me know if you have questions regarding my review of the referenced report <br />prepared by R Squared Incorporated and submitted for review to the Division by J. E. <br />Stover & Associates, Inc. <br />C: Sandy Brown <br />