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Marcia Talvitie <br />January 2, 2011 <br />Page 4 <br />13. Under the Present Groundwater Use section, WFC states that "Thirty four wells were <br />identified and are located as shown on Map 2.04.7 -5." It appears that only about 25 wells <br />are shown on this map. Please update the map accordingly. <br />14. The first paragraph at the top of page 13 should be corrected. WFC indicates that none of <br />the wells within a one mile radius of the NHN permit boundary draws its water from the <br />Dakota Formation. Three wells listed on the Table 2.04.7 -4 are indicated as completed in <br />the Dakota Formation. Although these are only monitoring wells that are operated by <br />Montrose County this statement should be clarified. Also in the same paragraph the last <br />sentence should be modified. The Burro Canyon Formation further isolates the Brushy <br />Basin Member of the Morrison Formation, and WFC has illustrated the Burro Canyon <br />Formation on Geologic Cross - Sections A -A' and B -B'. Therefore, it would be <br />appropriate to add the following to the end of the Iast sentence in the first paragraph of <br />page 13: "...and mudrock of the Burro Canyon,Forrnation." <br />15. On Map 2.04.7 -1, Spoil Springs (SS #1 -3) should be added to the legend. Also on this <br />map the 2nd Park Lateral should be designated with a different symbol than the same one <br />used for the natural drainages Glasier, Meehan, and Nygren Draws. <br />16. It is unnecessary to have a Probable Hydrologic Consequences section under 2.04.7, but <br />WFC has included a summary of the PHC in this section. The Division has noted the <br />following inconsistencies. In the last paragraph on page 21, WFC states that <br />"...Recharge from irrigation (the only source of recharge) will continue..." This should <br />be changed to "...Recharge from irrigation (the primary source of recharge) will <br />continue..." Also there is no discussion of the occurrence of spoil springs in this entire <br />section, pages 21 through 24 of 2.04.7. <br />17. The Division of Water Resources has reviewed the NHN permit application and has <br />provided written comments. The State Engineers Office has expressed several concerns <br />with the project including the following: 1) The potential for exposing groundwater <br />during sediment pond excavation, 2) Permitting requirements for drilling a new <br />domestic /industrial use well and for nine existing monitoring wells, 3) Application for <br />surface water rights and for an augmentation plan, 4) Reporting procedures for well <br />abandonment, and 5) Diversion of the Second Park Lateral Ditch. Please refer to the <br />enclosed comment letter from the Division of Water Resources, Office of the State <br />Engineer dated November 23, 2010. Please address each of these concerns and provide a <br />response and amended application materials, if appropriate. <br />2.05.6(3) Protection ofhydroloQical balance <br />18. WFC provided a detailed analysis of the "Probable Hydrological Consequences of <br />Mining" in the application package. Substantial discussion and analysis is provided for <br />spoil springs tributary to Tuttle Draw. But very Iittle analysis was provided for the <br />predicted spoil springs that may be tributary to Meehan Draw from the mineable block <br />