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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 Page 25 <br />Creek. Please include a PHC analysis for the mine water discharge and its potential to <br />impact tributaries, shallow alluvial groundwater, and East Salt Creek. <br />65. On page 2.05-104 CAM describes overlying Upper and Lower perched aquifers above the <br />flooded mine workings. On 2.05-105 CAM further states that "...mine water seepage into <br />the upper or lower perched water bear zones would improve the water quality in both zones. <br />There is no hydrology description provided for these aquifers in Section 2.04.7 and it is <br />unclear which water bearing formations are being described in the PHC discussion. Please <br />clarify the upper and lower perched aquifers described in this section and update Section <br />2.04.7 accordingly. <br />66. No specific PHC predictions were given for the water above the Cameo Seam and water <br />below the Cameo Seam. These units are briefly desribed with regard to water quality on <br />page 2.05-104. There is water present above and below the Cameo coal seam as indicated <br />by wells 7-34-7 and 8-2-8, respectively and the Cameo coal seam itself is saturated at least <br />in the northeast portion of the permit area and in adjacent areas to the east. Please revise the <br />PHC analysis to include a discussion and specific PHC predictions for the water above, <br />within, and below the Cameo Seam. <br />Rule 2.05.60)(b)(iv) Hydrologic Monitoring Plan <br />67. The Hydrologic Monitoring Plan is given on page 2.05-109. The plan for stock ponds <br />does not include any water quality analysis or field parameter measurements. The plan as <br />proposed, only calls for either freeboard or water depth measurements. This is not <br />adequate to identify potential impacts and to ensure the protection of the quality of <br />surface water within the proposed permit and adjacent areas. As discussed above for the <br />baseline monitoring plan, any downstream stock ponds that could receive flows or <br />otherwise be impacted by mining should have water quality samples taken for laboratory <br />analysis. The Division is requesting that CAM reevaluate the baseline monitoring plan <br />for stock ponds (see Item 20 above). Likewise, the ongoing monitoring plan for stock <br />ponds should be amended accordingly to include laboratory analysis for those select <br />ponds. An annual laboratory analysis would suffice for the continued monitoring plan. <br />The Division also recommends that the Hydrologic Monitoring Plan be amended on page <br />2.05-109 for stock ponds to include the collection of field parameters (pH, temperature <br />and conductivity) on a quarterly schedule. <br />68. The springs identified in Section 2.04.7 of the PAP need to be included in the Hydrologic <br />Monitoring Plan. Please amend the Hydrologic Monitoring Plan in Section 2.05.6(3) of <br />the PAP to include a monitoring plan and schedule for sampling the springs within and <br />adjacent to the permit areas. <br />69. Please update the surface water sampling parameter list on page 2.05-112 to include total <br />and dissolved iron.