2011-05-16_REVISION - C1981012

• Permit No: C1981012
• IBM Index Class Name: REVISION
• Doc Date: 5/16/2011
• Doc Name: Adequacy Review No. 2
• From: AGAPITO Association, Inc
• To: DRMS
• Type & Sequence: TR56
• Email Name: KAG
• Media Type: D
• Archive: No

A AGAPITO ASSOCIATES, INC.
Mining & Civil Engineers & Geologists
715 HORIZON DR., STE 340 GOLDEN OFFICE
GRAND JUNCTION, CO 81506 303.271.3750
USA
VOICE 970.242.4220
www.agapito.com r"' '.. VED
May 13, 2011 `Ir?(1 6 2011 723-01 T1
Mr. Kent Gorham '. ,Iv I +?ectamatian,
Colorado Division of Reclamation, Mining and Safety Mining and Sale
1313 Sherman Street, Room 215
Denver, CO 80203
Re: New Elk Mine (Permit No. C-1981-012)
Technical Revision No. 56 (TR-56)
Incidental Boundary Change/Allen-Apache Mining
Adequacy Review #2 (May 5, 2011) Response
Dear Mr. Gorham:
This letter and supporting documents are submitted in response to a modification to the adequacy
response dated May 5, 2011. Your original questions and NECC's original response are shown in italics.
Adequacy responses to those items have been modified as follows.
Rule 2.04 Information on Environmental Resources
2. DRMS: Permit text narrative on pages 2.04-17 to 2.04-25 describe the groundwater hydrology
as required by Rule 2.04.7(1). Included in this section of text narrative are briefstatements with
regard to the impacts due to mining. While Rule 2.04.7(3) requires identification of the extent
that the operation may affect surface or underground sources of water put to beneficial use, the
detailed discussion of impacts should be quantified and summarized under Rule 2.05.6(3), rather
than included with the baseline hydrologic information. Please also modify permit text on page
2.04-1 lb indicating the 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
NECCResponse: 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.
GEOENGINEERING • MINING ENGINEERING • CIVIL ENGINEERING