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Colowyo, 01981 -019, PR3 adequacy No. 3 15 July 22, 2011 <br />This item has been resolved with the August 9, 2011 submittal. <br />2. Requirements for certified inspection reports are listed in Rule 4.05.9(14) and (15). Please <br />provide a reference within Rule 4 Section 4.05.9 of the application directing the reader to the <br />appropriate section of the application where the requirements of (14) and (I 5) have been <br />addressed. Alternatively. please revise Section 4.05.9 to incorporate these requirements. <br />This item has been resolved with the August 9, 2011 submittal. <br />Rule 4.05.13 Surface Water and Ground Water Monitoring <br />4. DBMS proposes that well MLC- 04 -Olbe established as an alluvial ground water point of <br />compliance, based on a) the probable discharges of spoil leachate to Colltrm Gulch after mining <br />is completed, and b) the discharges can be expected to have a high dissolved solids content <br />which could negatively impact the quality of alluvial ground water in Collura Gulch. The <br />leachate can be expected to have TDS concentrations greater than 3,000 mg/I, compared to <br />native alluvial ground water TDS generally less than 2,000 mo. <br />It; as CCC's response says, well MLC- 04 -0IC is inappropriate tier an alluvial ground water <br />point of compliance because of possible upstream non - mining impacts, then please either add <br />an additional well to the monitoring plan for distinguishing non - mining impacts, or propose <br />another well as an alluvial ground water point of compliance. Our letter of April 22, 2011 <br />explained the potential for activities proposed by PR -03 to negatively impact the quality of <br />alluvial ground water in Collom Gulch. Rule 4.05.13(1)(6) requires one or more points of <br />compliance for any coal operation that, in thejudgment of the Division, has the potential to <br />negatively impact the quality of groundwater for which quality standards have been established <br />by the Colorado Water Quality Control Commission (CWQCC). Rule 4.05.13(1)(b)(i(A) <br />requires a point of compliance for potentially impacted ground water that is subject to the <br />CWQCC's standards. Collom Gulch alluvial ground water is subject to the Interim Nanative <br />Standard of the Basic Standards for Ground Water, CWQCC Regulation 41 and, therefore, <br />needs a ground water point of compliance. <br />For the reasons stated in our letters of April 22 and July 22, 2011, please propose a well <br />location for a valley fill ground water point of compliance. Monitoring should begin prior to <br />disturbance. <br />5. DBMS does not propose establishing a ground water point of compliance for bedrock <br />hydrostratigmphic units. DRMS is considering the need for a bedrock ground water monitoring <br />well or wells that would not be established as points of compliance. DBMS will complete its <br />review of the proposed hydrologic monitoring plan after receiving the requested calculations of <br />pitwall seepage and spoil spring discharges. <br />Rule 4.05.13(I)(c) requires monitoring or ground water when surface mining activities may <br />affect ground water systems on or off the permit at The discussion of probable hydrologic <br />consequences in the PR -03 submittal describes potential dewutering of bedrock units during <br />