2011-05-05_REVISION - C1981012 (2)

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correct reference to the probable hydrologic consequences section (not section 2.04.7). Permit text on 2.04-24 also identifies wells that could be impacted. This type of information should be included and summarized in the PHC section of the permit application. Rule 2.04.7(3) should focus primarily on the alternative water supply available should contamination or diminution occur and water rights owned or leased by the operation. Exhibit 8(4) is inadequate with regard to a summary of all hydrologic impacts that are probable due to the proposed operations. Please review these pages along with Exhibit 8(4) and include a detailed summary of the probable hydrologic consequences of mining to surface and ground water quantity and quality. This summary should address the probable; • Impacts to groundwater quantity (both wells and springs) from subsidence; Impacts of mining to groundwater quality; • Impacts of mine water inflow and subsequent discharge to surface water quality, • Impacts of subsidence to surface water quantity; and • Impacts of mine water consumption to surface water users NECC Response: Text in sections 2.04.7(3) and 2.05.6(3) has been added and modified along with text in Exhibit 8(4) with regard to the probable hydrologic consequences. DRMS Response: Response partially accepted. The application remains deficient with regard to the details describing the water rights owned or leased by the mine and the estimated consumptive use. Page 2.04-33 discusses the replacement of bedrock well water due to mining. Page 2.05- 59 and 60 provides limited information regarding estimates of demand for water. The application does not provide sufficient detail regarding the water rights available to the operation. Information provided by the Division of Water Resources (DWR) indicates that the DWR Division 2 office may be working with NECC regarding the administrative exchange of up to 250 acre-ft per year from the City of Trinidad. The application provides no information regarding this exchange or other details on other water sources available to the operation. Rule 2.04.7(2)(a) specifically requires "the application shall also contain information pertaining to ownership and uses of surface water bodies." This Rule would include that information for the mine operation itself. Please find the letter from DWR attached (March 29, 2011). In particular, paragraphs two and four of the DWR letter should be reviewed and those issues outlined and addressed in permit text narrative and include other permitting materials, as necessary. The major areas that require additional detail include: 3 The estimated demand and the proposed water su I • Plans for future mine dewatering and need for a permit • Storage and use of pumped groundwater