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Corey Heaps <br />McClave Canyon Mining, LLC <br />February 15, 2011 <br />Page 4 <br />location of GW-9. Well GW -3 is nearly a mile down gradient and would not be adequate for <br />monitoring potential impacts to the shallow alluvial groundwater or East Salt Creek immediately <br />down gradient of the refuse pile. The Division believes that one additional monitoring point just <br />below the disturbance area associated with the refuse pile is warranted. Please provide a plan for <br />one additional monitoring well to be located immediately below the proposed waste pile location. <br />This well will serve to verify the conclusions presented in the PHC for potential impacts to <br />groundwater and East Salt Creek. <br />13. There is no discussion of groundwater points of compliance for the proposed project. Please <br />review your ground water monitoring program specific to establishing a groundwater point (or <br />points) of compliance for McClanc canyon Mine, and specify which well or wells will be <br />available as point of compliance well(s) for the alluvial groundwater. The PAP should address <br />the need for points of compliance and be updated accordingly. Well GW -3 may be appropriate <br />for this purpose. <br />14. The information for bedrock groundwater quantity and quality needs to be clarified and <br />updated. The three wells presented in the revised text for the water quality description are <br />located more than two miles up gradient from the affected area. There does not appear to be <br />any down dip monitoring of bedrock groundwater for the current or proposed mine workings. <br />MCM is required to present information for the strata above, within, and below the lowest coal <br />seam to be mined (if potentially impacted). There is very little information presented to assess <br />impacts to bedrock groundwater from the mining operation. There is a description of mine <br />inflow water which may serve to provide suitable monitoring of water quality in the coal seam. <br />Depending on the stratigraphy MCM may be able to make the case for no impact below the <br />lowest coal seam mined, but there is no information or discussion provided. Finally, at a <br />minimum it appears that the water bearing zone above the Cameo Coal seam should be <br />monitored at a down dip location. Please provide an adequate plan for bedrock groundwater <br />monitoring down gradient of the disturbed area proposed with PR -2 and update the bedrock <br />groundwater discussion accordingly. <br />15. Rule 2.04.7(1)(b) requires that the application provide well locations and reported yields from <br />all wells within the proposed permit and adjacent areas which are registered with the SEO. <br />Please add this information to the revised text in this section of the PAP. This information was <br />partially provided in two other sections including 2.04.7(3) Altemative Water Supply (page <br />2.04 -26) and 2.05.6(3) Protection of hydrological balance (page 2.05 -59) but the list of wells <br />within the permit and adjacent areas appears incomplete. Based on our review of the SEO <br />database these additional wells (CAM Colorado 270165 and 270164; #11 Enterprises 254050 <br />and 24505 1) located in the East Salt Creek drainage or adjacent areas should be added to the <br />list of wells registered with the SEO. Please review the SEO database and provide well <br />locations and reported yields from all wells within the proposed permit and adjacent areas <br />which are registered with the SEO in Section 2.04.7(1)(b) of the PAP. If appropriate please <br />also update Sections 2.04.7(3) and 2.05.6(3) with a more current list of wells. <br />16. In Table 4.2ii, please include baseline monitoring results for stations SW -2, SW -5 and, possibly <br />SW -4, since they are part of the approved surface water monitoring plan. Also, baseline <br />