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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 7 <br />descriptions of surface drainage systems sufficient to identify, in detail, the seasonal <br />variations in water quantity and quality. Further, Rule 2.04.7(2)(b)(ii) requires water <br />quality sampling and laboratory analyses be conducted for surface waters which will <br />receive flows from surface or ground water from affected areas within the proposed <br />permit area. Total iron was missing from the required parameter list (2.04.7(2) (b) (ii) <br />Item E) for the only laboratory sample collected from Pond 6. <br />It appears that several down stream stock ponds could receive flows from surface water <br />or otherwise be impacted by the mining operation including but not limited to Ponds P-5, <br />P-10, P-13, and P-21. Pond 2 in particular is located immediately on the mine water flow <br />path proposed for the mine discharge (although the embankment has been washed out <br />according to information provided in the PAP). Ponds 2, 13, 15, and 21 have the <br />embankment washed out and will not be included in the monitoring program. To avoid <br />confusion this should be designated on Map 9 Hydrologic Monitoring Location Map. <br />Based on our review of the baseline information it appears that several additional stock <br />ponds should have water quality samples taken for laboratory analysis. At a minimum <br />the Division recommends that field parameters (pH, temperature, and electrical <br />conductivity) be taken during the spring and fall at all stock ponds that are not dry. <br />Water quantity data is not consistently reported for many of the stock ponds. At six of <br />the ponds water depth measurements were taken. At all others that retained water, a <br />freeboard measurement was recorded. In some cases both freeboard and water depth was <br />measured at different times of the year. Consistent measurements (either freeboard or <br />depth) should be routinely taken from an established measuring point to document <br />baseline water quantity at the stock ponds. <br />The Division agrees with CAM that these are important hydrologic features and therefore <br />it is important to ensure that adequate baseline information be established prior to any <br />mining disturbance. Based on the above discussion, it does not appear that sufficient <br />baseline monitoring data have been collected to adequately characterize water quantity <br />and water quality in the stock ponds. Please reevaluate the baseline monitoring program <br />for the stock ponds to ensure compliance with 2.04.7(2). A revised baseline monitoring <br />program will be needed; and it is necessary that CAM continue to collect additional <br />baseline information to characterize seasonal variations in pond quantity and quality. <br />21. Springs that have been mapped in the permit and adjacent areas are described on page <br />2.04-30 and 31. Baseline water quantity and quality of the identified springs is discussed <br />briefly on page 2.04-31 but the baseline data that has been collected are not included in <br />Volume III Tab 3 of the PAP along with the other surface and groundwater baseline data <br />for the Red Cliff Mine. CAM must continue to collect additional baseline information to <br />characterize seasonal variations in quantity and quality at the springs and seeps identified <br />in the permit and adjacent areas. Where sufficient flow is available, the flow should be <br />measured and recorded and samples should be collected for laboratory analysis. If <br />sufficient flow is not present the water in the springs and seeps should be analyzed