Laserfiche WebLink
Tamme Bishop, P.E. <br />January 9, 2013 <br />Page 2 <br />The presentation in the revised text for both alluvial and bedrock water quality data needs <br />further clarification. Table 4.2 is confusing particularly with regard to the correlation <br />between the GW and MW nomenclature. Tables 4.2i and 4.2ii appear to contain the <br />same data for the same alluvial monitoring wells (Table 4.2i contains summary data). <br />This is not clearly described on pages 2.04 -17 and 18. There are also two Tables 4.2ii. <br />On page 2.04 -21 it is stated in the last paragraph that "A summary of the bedrock water <br />quality is contained in Table 4 -2ii, Groundwater Baseline Data. These data could not be <br />located. However, there is a second Table 4.2ii entitled Surface and Ground Water <br />Quality Monitoring (November 198 1) but the data for groundwater contained in the table <br />is clearly from alluvial wells as opposed to bedrock wells (e.g., the depth to water is at @ <br />38 feet for the 3 wells presented on the table). The text on pages 2.04 -17 through 21 <br />and the corresponding tables referenced therein should be more clearly explained. Please <br />revise the permit text and tables accordingly. <br />12. GW -10 was apparently added to the monitoring plan as reported in the 2011 AHR, but <br />then removed at some point during the PR -2 review process. The Division recently <br />received an abandonment report for GW -10. The sealing of this well should be added to <br />the permit text at the top of page 2.04 -18 and to Figure 4.2 -2. <br />13. At page 2.04 -18 MCM has proposed that monitoring well GW -3 will serve as the point of <br />compliance for the mining operations. Rule 4.05.13 requires that if the point of <br />compliance is not located in the permit area then other appropriate location shall be <br />agreed upon by the Division and the permittee. No point of compliance has been <br />proposed for bedrock groundwater. The Division would like to meet with the Operator to <br />discuss the need for points of compliance as suggested in Item 11 above <br />14. The Operator has made a case for not monitoring deep bedrock groundwater down <br />gradient of the permit area due to the economic and technical impracticality of installing <br />wells in areas of rugged terrain and excessive overburden combined with low <br />transmissivity values and an overall lack of groundwater at these depths. Based on our <br />review of the permit document and revised pages submitted for PR -2 it appears that the <br />only data available for bedrock groundwater is limited to water level information. The <br />Division cannot locate the bedrock water quality data referenced on revised page 2.04 -21. <br />Let's plan to review the existing bedrock water quality data and the need for additional <br />monitoring during our upcoming meeting. No further response is necessary at this time. <br />24. The text on Page 2.04- 33(1)(c) refers to Figure 4.4 -2 for the soil sampling locations. <br />Figure 4.4 -2 submitted with the PR -2 application on November 1, 2010 delineates the <br />water sampling locations. The text should refer to Appendix T — Figure 1 for the the soil <br />sampling locations for the proposed expansion area. Please amend the text on page 2.04- <br />33 to refer to the correct figure. <br />65. When comparing the Topsoil Salvage Volume chart on page 2.05 -26 and the Topsoil <br />Replacement Volumes chart on page 2.05 -27, it shows that the final distribution of the <br />topsoil will be significantly different than the salvaged distribution. Please clarify the <br />