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Marcia Tatvitie <br />January 2, 2011 <br />Page 5 <br />located to the north of Meehan Draw. The Division has identified this as a potentially <br />significant impact and an adequate analysis is not provided. Springs tributary to Meehan <br />Draw are first mentioned on page 2 of Section 2.05.6(3) and springs and seeps are shown <br />on Figure 2.05.6(3) -1 to potentially discharge from the "Saturated NHN Backfill ", but no <br />further predictions of flow or TDS concentrations are provided. Please update all <br />pertinent sections contained within the protection of the hydrologic balance and probable <br />hydrologic consequences discussions and data analysis with information on potential <br />spoil springs tributary to Meehan Draw. The same level of detail should be provided for <br />Meehan Draw as presented for Tuttle Draw. <br />19. There is very little discussion or analysis of Coal Creek Canyon. Please update Section <br />2.05.6(3) with a complete analysis of potential impacts to Coal Canyon resulting from the <br />potential for spoil spring discharge to Meehan Draw which flows to Coal Creek Canyon <br />and ultimately discharges to the San Miguel River. The analysis should provide <br />predictions for TDS concentrations and flow information for the potential impacts to Coal <br />Canyon. <br />20. On pages 11 and 15 there is a discussion of the 2 nd Park Lateral being diverted around the <br />mining area in a HDPE pipeline. Please clarify in this section when the 2nd Park Lateral <br />will be restored and what specific effect that will have on groundwater flow. Also clearly <br />describe whether or not the pipe will be removed or retained and whether the ditch will <br />be placed back in its approximate original configuration. <br />21. On page 13, WFC describes 30 ground water rights (wells) that have been identified; <br />however, this conflicts with the information presented earlier in Section 2.04.7. Under <br />the Present Groundwater Use section (page 11 and Table 2.04.7.4 of Section 2.04.7) <br />WFC states that thirty four wells were identified. Please clarify this discrepancy. <br />22. Please provide an estimate of flow and TDS concentrations for all potential future spoil <br />springs. Provide the predicted locations for all future spoil springs to Meehan Draw and <br />Tuttle Draw and clearly label them on an appropriate map. <br />23. Section 3) Impact of Spoil Material on Groundwater Flow and Recharge beginning on <br />page 14 again minimally discusses springs tributary to Tuttle Draw and springs tributary <br />to Meehan Draw. The discussion for Tuttle Draw should clearly identify what the <br />predicted flow and TDS concentrations will be for the future spoil springs that may <br />occur. Sections 3 and 5 of the PHC (pages 14 through 22) need to be updated <br />accordingly with predicted TDS and flow rate information for springs tributary to <br />Meehan Draw and any impacts to Coal creek Canyon. <br />24. On page 17 it would be appropriate to add a description and prediction of the combined <br />effect of discharge that may occur from the new NHN Mine mixing with the "old <br />Backfill" (New Horizon #1 .Area) and ultimately discharging from the approximate <br />location of Spoil Spring #1. Please provide the cumulative prediction for the existing <br />flow from SS #1 when it is combined with the additional TDS concentration and flow <br />