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t <br />Mike Boulay <br />October 16, 2012 <br />MCM: The new coal mine waste disposal pile is no longer part of PR -02, and therefore <br />the additional point of compliance is not longer necessary. <br />13. There is no discussion of groundwater points of compliance for the proposed <br />project. Please review your ground water monitoring program specific to <br />establishing a groundwater point (or points) of compliance for McClane <br />canyon Mine, and specify which well or wells will be available as point of <br />compliance well(s) for the alluvial groundwater. The PAP should address <br />the need for points of compliance and be updated accordingly. Well GW -3 <br />may be appropriate for this purpose. <br />MCM: Please see discussion beginning on page 2.04 -18. <br />14. The information for bedrock groundwater quantity and quality needs to be <br />clarified and updated. The three wells presented in the revised text for the water <br />quality description are located more than two miles up gradient from the affected <br />area. There does not appear to be any down dip monitoring of bedrock <br />groundwater for the current or proposed mine workings. MCM is required to <br />present information for the strata above, within, and below the lowest coal seam <br />to be mined (if potentially impacted). There is very little information presented to <br />assess impacts to bedrock groundwater from the mining operation. There is a <br />description of mine inflow water which may serve to provide suitable monitoring <br />of water quality in the coal seam. Depending on the stratigraphy MCM may be <br />able to make the case for no impact below the lowest coal seam mined, but there <br />is no information or discussion provided. Finally, at a minimum it appears that <br />the water bearing zone above the Cameo Coal seam should be monitored at a <br />down dip location. Please provide an adequate plan for bedrock <br />groundwater monitoring down gradient of the disturbed area proposed with <br />PR -2 and update the bedrock groundwater discussion accordingly. <br />MCM: Down gradient bedrock monitoring wells are addressed in section 2.04.7. The <br />Operator does not believe it is economically or technically practicable to install <br />down gradient bedrock monitoring wells northeast of the proposed mine plan <br />area. Please see discussion beginning on page 2.04 -21. <br />15. Rule 2.04.7(1)(b) requires that the application provide well locations and reported <br />yields from all wells within the proposed permit and adjacent areas which are <br />registered with the SEO. Please add this information to the revised text in this <br />section of the PAP. This information was partially provided in two other sections <br />including 2.04.7(3) Alternative Water Supply (page 2.04 -26) and 2.05.6(3) <br />Protection of hydrological balance (page 2.05 -59) but the list of wells within the <br />permit and adjacent areas appears incomplete. Based on our review of the SEO <br />database these additional wells (CAM Colorado 270165 and 270164; #11 <br />Enterprises 254050 and 245051) located in the East Salt Creek drainage or <br />adjacent areas should be added to the list of wells registered with the SEO. <br />Please review the SEO database and provide well locations and reported <br />