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describe the test(s) performed and describe the methodology for analyzing the data. This <br />information will aid in determining applicable discharge rates as requested in Item 4 above and <br />will allow for a more complete evaluation of potential groundwater impacts and the probable <br />hydrologic consequences. <br />Response - GW-N27 is in the old backfill and shows what the expected flow rate will be in <br />the "spoils': The text in this section has been revised and the reference to New Horizon <br />Mine 2 permit has been taken out. Reference was made to the New Horizon 1 and New <br />Horizon 2 permits in the previous submittal because that was the understanding WFC <br />reached with CDRMS in meeting June12, 2008 in Grand Junction when deciding if we <br />would submit "new permit" or extend existing permit. CDRMS said we could reference <br />the other permits to reduce the prep time and volume of the "new"permit <br />6. Please revise the first sentence under Baseline Ground Water Quality on page 5 because it is <br />misleading. The Division does not approve baseline data collection plans prior to the submittal <br />of a new permit application package. The Division discussed the proposed sample plans with <br />WFC on several occasions in meetings and on the telephone during the planning stages in <br />preparation for submittal of the permit application. The Division only gives approval of <br />applications or plans through the proposed decision process. Please revise the first sentence of <br />the last paragraph of page 5 as follows: "...the planned hole locations, completion techniques, <br />water quality sampling schedules and the water quality sample parameters were discussed with <br />CDRMS for their input and guidance." Please also correct the typo in the first line of that <br />sentence. Map 3.04.7-1 should be changed to Map 2.04.7-1. Wording added and correction <br />made. <br />Response -Wording was added and the typo was corrected <br />7. )AFC has done a good job with their initial baseline data collection efforts for ground water <br />information with regard to monitoring well depths and locations. These are consistent with the <br />discussions held with WC regarding groundwater monitoring sites during the planning phases <br />of this project. However, additional down gradient monitoring and a point of compliance <br />well(s) may be required. The Division agrees with WFC's assessment that there are no current <br />users for the relatively small amount of groundwater that is currently moving through the <br />shallow bedrock zones, overburden and coal toward the crop line to the southwest. Because <br />this groundwater is potentially usable it must be monitored and the extent and magnitude of any <br />mining impacts must be determined. Given the information we now have as provided on <br />geologic cross-sections, piezometric level maps, and the disturbance boundary as shown in the <br />application the Division believes that one additional group of nested wells may be warranted. <br />The reason for this is that the full extent of the disturbed area is not being monitored in the <br />downgradient direction (i.e., the southwest end of the southernmost mineable block). WFC has <br />other existing monitoring wells in this general vicinity that may be suitable and could <br />potentially be included in the monitoring plan for this purpose. <br />Additionally, there is no discussion of groundwater points of compliance for the proposed <br />project. Please review your ground water monitoring program specific to establishing a <br />groundwater point (or points) of compliance at the New Horizon North Mine, and specify <br />which well or wells will be available as point of compliance well(s). The PAP should <br />Response to First Adequacy Review Page 17