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Mr. Gary Isaac <br />May 5, 2008 <br />Page 3 <br />term. Figure 1 of the AVF study shows a mine discharge location in the northern portion of the <br />Study Area Boundary which does not appear to be consistent with the mine water discharge <br />discussions given in sections 2.04.7 and 2.05.6. <br />Some discussion regarding potential impacts to East Salt Creek is given on page 2.05-107 where <br />based on TDS data from mine water discharge from McClane Canyon Mine it is concluded that <br />"mine discharge, should it occur, would only improve the quality of water in East Salt Creek with <br />regard to salt content. On page 2.05-107, CAM-Colorado also states "Water discharged from <br />Red Cliff mine will eventually enter East Salt Creek after flowing through approximately 6.5 <br />miles of ephemeral channels." There is no mention of specific discharge location(s) and there is <br />no plan in place to handle and convey mine discharge in the event it is necessary during the first <br />permit term. Further, there is no discussion of future mine water discharge. <br />The permit application lacks information regarding the handling, treatment and discharge of mine <br />water. The application does not describe where the water will be discharged and what potential <br />impacts could result from mine water discharge to downstream tributaries or shallow alluvial <br />groundwater. In section 2.05.6(3) Protection of hydrological balance page 2.05-100, CAM- <br />Colorado briefly states "Any discharge from the mine or mine facilities will be treated to meet <br />CDPS discharge permit requirements." It is unclear whether or not the discharge will be treated <br />by a sedimentation pond or discharged directly to an ephemeral drainage. More information <br />needs to be provided regarding the potential for mine discharge to East Salt Creek during the first <br />permit term and subsequent permit terms. <br />Each application requires the location of each conveyance, treatment, storage, and <br />discharge facility to be used within the permit area. In accordance with Rule 2.05.6(3) (b) <br />(vi), please identify the specific location where mine water will be discharged. Please update <br />pertinent sections of the permit application with a detailed plan for handling the mine water <br />discharge and describe how discharge standards will be met. If the discharge is not <br />conveyed through a sedimentation pond, provide a plan for meeting applicable discharge <br />standards including a copy of the CDPS discharge permit, if applicable. If mine water is <br />not treated by a sediment pond and discharged to an ephemeral drainage, then the <br />application shall contain a description and map of the discharge point and the <br />characteristics of the receiving water [Rules 2.04.5(1) and 2.04.7(2)(a)]. <br />4. Potential impacts to Big Salt Wash where the majority of the areas coal reserves lie are not <br />specifically addressed by this permit application. On page 2.05-108 it is stated "Big Salt Wash <br />will not be impacted during the initial permit term. As the mine plan is expanded to the east <br />through future permit revisions, there will be a potential to impact Big Salt Wash." The probable <br />hydrologic consequences section of the application incompletely assesses the potential impacts <br />and affects to the Big Salt Wash drainage. The Division will need the estimated life of mine plan <br />regarding expansion to the east towards Big Salt Wash and information on mine water discharge <br />quantity and quality specifically addressed in the PHC. <br />