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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 8 <br />quarterly for field parameters (pH, temperature, and conductivity) when possible. Please <br />tabulate and incorporate all field and laboratory data collected to date from springs and <br />seeps into the Baseline Water Monitoring Data, Volume III. <br />22. As noted in our May 5, 2008 completeness review letter, the baseline surface water data <br />presented for East Salt Creek is lacking some of the minimum parameters required by Rule <br />2.04.7(2). For ESC-1 both total and dissolved iron are required and at ESC-2 total <br />suspended solids, total and dissolved iron, and manganese are missing from the analyses. <br />Dissolved iron is missing from samples collected from Big Salt Wash, Munger Creek, and <br />SW-1 through SW-3. For future baseline data collection efforts for all surface waters <br />including stock ponds and springs, please ensure that samples collected for laboratory <br />analysis are analyzed for the minimum parameters required by Rule 2.04.7(2)(b)(ii). <br />23. At the bottom of page 2.04-16 well #256861 is referred to as having a 12 gpm pumping <br />rate, but the information tabulated in Volume III, Tab 2 indicates that the water level is at <br />12 feet and the pumping rate is N/A. Our review of this well permit indicates that water <br />was encountered during drilling at 66 and 87 feet, no static water level was measured, <br />and the pumping rate was 12gpm. Please ensure that the well depth, water level, and <br />pumping rate information tabulated for the Water Rights Summary for wells is accurate <br />and complete. Please also include in the summary all available well completion <br />information such as ground surface elevation and perforated casing interval. <br />24. Hydraulic properties are estimated for the alluvium along Big Salt Wash, but no <br />information is provided on the recharge, storage, and discharge characteristics of the East <br />Salt Creek alluvium. Further, there is no baseline water quality provided for the East Salt <br />Creek or Big Salt Wash alluvium. Baseline water quality has been provided for two <br />alluvial wells VB06-03 and VB-06-10 but it is clearly stated in the PAP (page 2.04-17) <br />that the water in these alluvial wells is not representative and not hydrologically <br />connected to East Salt Creek or Big Salt Wash. These wells for which baseline alluvial <br />groundwater data have been provided monitor a localized thin veneer of alluvial <br />sediments atop the Mancos Shale. Water quality in samples taken from these wells <br />would be expected to be poor. <br />The mine plan, as proposed in the PAP appears to have the potential to negatively impact <br />the East Salt Creek alluvium. There does not appear to be the potential for impacts to Big <br />Salt Wash alluvium with the current proposed mine plan. As stated on pages 2.04-16 and <br />2.04-19, "In the lower reaches of the drainages generally south of the mine, the alluvial <br />groundwater may discharge to the creeks because of shallow water table conditions", and <br />"Within the permit and adjacent area, only East Salt Creek has saturated alluvium". <br />There is no discussion provided in the Hydrology Description or in the Probable <br />Hydrologic Consequences sections of the PAP regarding what potential impacts could <br />result from mine water discharge to downstream tributaries or shallow alluvial <br />groundwater.