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gates are in the closed position when a major storm occurs. The rationale for this <br />modeling methodology is also explained in Appendix 2.05.3(4) -1 of the New Horizon <br />North permit application package, beginning on page 4. <br />WFC Response: SEDCAD run evaluations for the following four cases, including 10yr -24hr event <br />with 2 - 6" weep holes wide open and weep holes closed, and 25yr -24hr event with 2 - 6" weep <br />holes wide open and weep holes closed were run and the results are included with this <br />application. In both 10yr -24hr and 25yr -24hr precipitation event cases where the weep holes are <br />fully opened, the settleable solids concentration discharge is less than the 10yr -24hr event <br />effluent limit of 0.5m1 /I. <br />All four SEDCAD run cases, including weep holes closed, result in no discharge through the <br />emergency spillway. <br />2. The as -built designs for pond NHN -001 include a revised Eroded Particle Size <br />Distribution (EPSD), labeled "New Horizon Mine 1 ". This EPSD differs from the <br />previously approved EPSD for NHN -001, and is also dissimilar to any of the EPSDs in <br />the approved New Horizon Mine 1 and 2 designs also labeled "New Horizon Mine 1 "). <br />Please explain the basis for this distribution. If this particle distribution is based on site <br />soil samples, please provide a copy of the laboratory report used for the distribution. <br />WFC Response: The ESPD in the four SEDCAD runs included with this application has been <br />revised to match the previously approved ESPD for Pond NHN -001. <br />3. Page 5 of Section 2.05.3(4) of the approved permit application package notes that mine <br />water, at a rate of 1 -2 cfm, may be pumped from the pit to Pond 001, 002, or 003. This pit <br />water inflow does not appear to be accounted for in the SEDCAD design, as required by <br />Rule 4.05.6(3)(a). Please either revise the SEDCAD design to include this base <br />flow /permanent pool (Rule 4.05.9(2)), or state that pit pumping will only occur when <br />the sediment pond is at or below the weep hole elevation and that the pond will be <br />dewatered within 24 hours. It should be clear that in no case will pit water pumped into <br />the pond result in the passage of runoff from the 10 -year 24 -hour event through the <br />emergency spillway (Rule 4.05.9(2)(b)). <br />WFC Response: All four SEDCAD run cases included with this submittal were run using a <br />designed null structure #1 with watershed information set to simulate approximately 2 cfs (1.96 <br />cfs) of pit water pumping, with the initial pool elevation at 5,671.5 ft., the gated valve elevation. <br />SEDCAD calculated no discharge through the emergency spillway for all four cases. <br />4. The placement of the primary spillway in the as -built configuration of pond NHN -001 <br />differs from the design. The spillway has been placed west of the approved location, <br />closer to the inlet of Ditch NHN -001 West. This location may result in short- circuiting of <br />the pond. Please indicate, in accordance with Ride 4.05.6(6), how WFC will ensure that <br />the pond is not short- circuited with Ditch NHN -001 West inflows. <br />WFC Response: The approved Pond NHN -001 principle spillway was located approximately 290 <br />feet from the inlet of Ditch NHN -001 West. The as -built principle spillway was relocated to <br />accommodate alignment with the existing county road culvert, and is approximately 215 feet from <br />the inlet of Ditch NHN -001 West. This distance is closer than the approved design of Pond NHN - <br />001, but exceeds the distance approved by DRMS in the design for Pond NHN -002, which shows <br />2 <br />