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<br />Mike Boulay -40- April 11, 2011 <br />91. There is no discussion of groundwater points of compliance for the proposed <br />project. Please review your ground water monitoring program specific to <br />establishing a groundwater point (or points) of compliance at the Frulta <br />Loadout, and specify which well or wells will be available as point of <br />compliance well(s) for the alluvial groundwater. The PAP should address the <br />need for points of compliance and be updated accordingly. <br />CAM: There is a discussion on points of compliance under 2.05.6(3)(b)(iv), page 2.05- <br />54, first paragraph, that states, "The applicant asserts the coal operation does not have <br />the potential to negatively impact the quality of groundwater for which quality standard <br />have been established by the Water Quality Control Commission". However, RW-3 is <br />available as a point of compliance, as stated in section 2.05.6(3)(b)(iv). <br />92. Under the surface water analysis of page 2.05-52, there is no discussion of the <br />amount of discharge from the sediment ponds. A value of 100 gallons per minute <br />is given in the table of parameters on page 2.05-52 but it is unclear how this was <br />calculated. It appears that Pond 4 is the only pond designed to passively <br />discharge and the remainder of the ponds will be dewatered by pumping. How <br />was the 100 gallons per minute calculated and does this account for all five ponds? <br />CAM : Each pond will be dewatered by pumping. A value of 100 gallons per minute is <br />an assumed value that is reasonable for a 2" gas powered pump. It is unknown at <br />this time the exact pump that will be used, but 100 gallons per minute is a good <br />assumption for comparison purposes. Text has been added to page 2.05-54 <br />noting the use the assumption. <br />93. There is no discussion of the Colorado River in the PHC. CAM is proposing to <br />divert water from Loma Drain and Reed Wash and there are proposed discharges <br />to Reed Wash. Since the site is in close proximity to the Colorado River and both <br />Loma Drain and Reed Wash ultimately drain to the river there should be some <br />conclusion and quantification of impacts (if any) added to the PHC <br />discussion for the Colorado River. <br />CAM: There is a discussion of the Colorado river under section 2.05.6(3)(b)(iv), <br />page 2.05-55, the Operator states, "The Colorado River will not be monitored <br />because of its high flow rate. Any potential impacts to the Colorado River could <br />not be detected because of the high dilution factor". <br />94. In the Probable Hydrologic Consequences Section 2.05.6(3)(b)(iii) on permit text <br />pages 2.05-49 and 2.05-50, it is stated that surface water is unlikely to recharge <br />the alluvial ground water system and some general assumptions are provided.