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Mike Boulay -2- June 20, 2008 <br />discharge from the mine was clarified on page 2.05-100. The PHC regarding the <br />impacts of mine discharge were clarified on page 2.05-107. <br />3. DRMS - CAM-Colorado has shown that mine inflow will occur during year six of <br />the life-of-mine operation. Further, the AVF Study states the following... "Red <br />Cliff expects to produce about 250 gpm of water that will be discharged into the <br />drainage below the mine portal." However, as required by Rule 2.05.6(3)(b)(vi) <br />the application still does not provide a description of the location of the mine <br />water discharge facility to be used within the permit area. Additionally the <br />application lacks a sufficient description and map prepared in accordance with <br />2.10 and 2.04.7(4)(a) of the locations of surface waters which will receive <br />discharges from affected areas, and any water which will receive discharges of <br />water from the general area [2.04.5(1)], and in accordance with 2.04.7(2)(a) the <br />location of any water discharge into any surface body of water. Thus, CAM- <br />Colorado has not minimally addressed the requirements of 2.04.7 and 2.05.6(3). <br />CAM - The discussion regarding the predicted mine water discharge was <br />amended on page 2.04-22. Amended Map 23 shows surface waters which will <br />receive discharge from affected areas. The mine discharge point is shown on <br />Map 23. Additionally, the AVF Study was amended and is enclosed. <br />4. No response required. <br />5. No response required. <br />6. Surface water information required by Rule 2.04.7(2) includes the location of all <br />surface water bodies including springs. If appropriate, the Division may also <br />require the seasonal variations water quality and quantity at spring locations <br />within and adjacent to the permit area. CAM indicates that a few springs exist but <br />provides no other information. In CAM-Colorado's response, our comment <br />regarding a spring and seep survey is noted, but no data were provided. Since <br />no data whatsoever were provided, CAM-Colorado has failed to minimally <br />address the requirements of 2.04.7(2) Surface water Information regarding <br />springs. Because seasonal variations in these water bodies may need to be <br />identified, the timing of a spring and seep survey and subsequent data collection <br />could become time-critical. For this reason the Division believes that this should <br />be addressed now as a completeness issue rather than as an adequacy issue. <br />For the application to be deemed complete CAM will at a minimum be required to <br />submit a spring seep survey of the permit area and adjacent areas and locate <br />them on an appropriate map. <br />CAM - Springs are discussed on amended pages 2.04-30 and 31. The springs <br />are located on Map 9.