Laserfiche WebLink
Mr. Gary Isaac <br />May 5, 2008 <br />Page 4 <br />Please update the permit application sections 2.04.5, 2.04.7, and 2.05.6. to include an impact <br />analysis for Big Salt Wash. The Division will need this information for input to a <br />Cumulative Hydrologic Impact Analysis (CHIA) for the entire life of mining operation. The <br />PHC information and the CHIA will have to address impacts to both Big Salt Wash as well <br />as East Salt Creek. <br />5. It is stated in the application that "The coal seam analytical data are obtained from two grab <br />samples from the McClane Canyon Mine and some historic information from Snowcap Coal <br />Company's permit." The geochemical analyses of the coal seam and strata above and below the <br />coal seam are presented in Volume III, Exhibit 6. Rules 2.04.6(3) (iii) and (iv) require site <br />specific geologic baseline information for the lands within the permit area. Rule 2.04.6(3) (b) does <br />allow an applicant to request the Division to waive in whole or in part these requirements. The <br />waiver maybe granted only if the Division makes a written determination that the collection and <br />analysis of such data is unnecessary because other equivalent information is available to the <br />Division in a satisfactory form. To consider the application complete, the required site specific <br />geologic data is needed or a waiver request justifying the reasons why CAM-Colorado believes <br />site specific data is not necessary. <br />Additionally the following information and submittal requests (Items 6 through 11) will be needed for the <br />Division to complete a thorough adequacy review of the permit application package. <br />6. Rules 2.04.7(1) & (2) require location information and descriptions of all springs within the <br />permit and adjacent areas. Very little information is provided on the occurrence of springs in the <br />area. On page 2.04-9, CAM-Colorado indicates "...only a few springs exist within the coal <br />bearing strata." In accordance with 2.04.7 and 2.05.3 please provide a spring and seep survey <br />for the entire estimated life of mine operations area and clarify the location of the springs <br />referenced on page 2.04.9. <br />7. The baseline surface water data presented for East Salt Creek appears to be lacking the some of <br />the minimum parameters required by Rule 2.04.7(2). For ESC-1 both total and dissolved iron are <br />required and at ESC-2 total suspended solids, iron, and manganese appear to be missing from the <br />analyses. If these data are available please update Volume III, Exhibit 3 accordingly. <br />8. The Alluvial Valley Floor Determination presented in Volume III, Exhibit 12 does not specifically <br />include the information identified by our Division in a letter dated May 22, 2006 regarding our <br />informal alluvial valley floor findings. The AVF study also appears to be lacking detailed <br />operational information (for example mine water discharge locations). There are two areas of <br />alluvium that need to be addressed one along East salt Creek and one along Big Salt Wash. These <br />specifically are where mine water discharge enters East Salt Creek down to the Highline Canal. <br />Likewise, to the east where mine discharge would likely enter into Big Salt Wash down to the <br />Highline Canal. The Division believes that AVF Study needs to be revised to include these <br />