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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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Last modified
8/24/2016 4:34:06 PM
Creation date
6/3/2011 8:50:28 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
APPLICATION CORRESPONDENCE
Doc Date
6/2/2011
Doc Name
Response to Preliminary Adequacy Review
From
Western Fuels Association
To
DRMS
Email Name
MLT
SB1
Media Type
D
Archive
No
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8. In the second paragraph on page 9 of Section 2.05.6(3), it is stated that water augmentation <br />during the irrigation off season will not be required. However, it is stated elsewhere in the <br />permit text that off season water is diverted into the irrigation system to fill cisterns etc. <br />Please explain why water augmentation would not be needed during the irrigation off <br />season. <br />Response - Within the mine permit, irrigation will cease prior to and during mining. <br />Water augmentation during off season would not be required since off season ditch runs <br />for filling cisterns and stock ponds will continue unabated through the HDPE pipeline <br />that will be in place to divert the 2nd Park Lateral irrigation flow A statement to this effect <br />has been added in the text. <br />9. WFC provided a detailed analysis of the "Probable Hydrological Consequences of Mining" <br />in the application package. Substantial discussion and analysis is provided for spoil springs <br />tributary to Tuttle Draw. But very little analysis was provided for the predicted spoil springs <br />that may be tributary to Meehan Draw from the mineable block located to the north of <br />Meehan Draw. The Division has identified this as a potentially significant impact and an <br />adequate analysis is not provided. Springs tributary to Meehan Draw are first mentioned on <br />page 2 of Section 2.05.6(3) and springs and seeps are shown on Figure 2.05.6(3)-1 to <br />potentially discharge from the "Saturated NHN Backfill", but no further predictions of flow <br />or TDS concentrations are provided. Please update all pertinent sections contained within <br />the protection of the hydrologic balance and probable hydrologic consequences discussions <br />and data analysis with information on potential spoil springs tributary to Meehan Draw. The <br />same level of detail should be provided for Meehan Draw as presented for Tuttle Draw. This <br />will be revised as suggested. <br />Response - The text has been revised as suggested Information and discussion added see <br />pages 26, 27, 28 and Table 2.05.6(3)-2. <br />10. There is very little discussion or analysis of Coal Creek Canyon. Please update Section <br />2.05.6(3) with a complete analysis of potential impacts to Coal Canyon resulting from the <br />potential for spoil spring discharge to Meehan Draw which flows to Coal Creek Canyon and <br />ultimately discharges to the San Miguel River. The analysis should provide predictions for <br />TDS concentrations and flow information for the potential impacts to Coal Canyon. <br />Response -Access to Coal Canyon is difficult and limited, however Coal Canyon was <br />sampled on 317111. The sample data was used in a discussion of the effects on Coal <br />Canyon in Section 2.05.6(3). Regular monitoring of Coal Canyon is not planned. <br />11. On pages 11 and 15 there is a discussion of the 2°d Park Lateral being diverted around the <br />mining area in a HDPE pipeline. Please clarify in this section when the 2"d Park Lateral will <br />be restored and what specific effect that will have on groundwater flow. Also clearly <br />describe whether or not the pipe will be removed or retained and whether the ditch will be <br />placed back in its approximate original configuration. <br />Response - The pipe will be re-located in the approximate original location of the ditch <br />during the reclamation phase. Water percolation from the ditch flow itself will be <br />Response to First Adequacy Review Page 47
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