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Mike Boulay <br />-2- March 8, 2013 <br />The presentation in the revised text for both alluvial and bedrock water quality data <br />needs further clarification. Table 4.2 is confusing particularly with regard to the <br />correlation between the GW and MW nomenclature. Tables 4.2i and 4.2ii appear to <br />contain the same data for the same alluvial monitoring wells (Table 4.2i contains <br />summary data). This is not clearly described on pages 2.04 -17 and 18. There are also <br />two Tables 4.2ii. On page 2.04 -21 it is stated in the last paragraph that "A summary of <br />the bedrock water quality is contained in Table 4 -2ii, Groundwater Baseline Data. <br />These data could not be located. However, there is a second Table 4.2ii entitled <br />Surface and Ground Water Quality Monitoring (November 1981) but the data for <br />groundwater contained in the table is clearly from alluvial wells as opposed to bedrock <br />wells (e.g., the depth to water is @ 38 feet for the 3 wells presented on the table). The <br />text on pages 2.04 -17 through 21 and the corresponding tables referenced therein <br />should be more clearly explained. Please revise the permit text and tables <br />accordingly. <br />MCM: Please see revised page 2.04 -17, text was added to clarify the information <br />presented on Tables 4.2i and 4.2ii. Text was added to Table 4.2 to further clarify the <br />correlation of wells. The GW nomenclature has historically been used by McClane, and <br />the MW nomenclature was used by Munger, however, in many cases, GW =MW. During <br />the TR -15 adequacy process we developed the correlation chart (Table 4.2) to try and <br />make the presentation less confusing and provide some consistency between the two <br />permits. In addition, the name of Table 4.2ii, 'Surface and Ground Water Monitoring' <br />has been changed to Table 4.2iii. Bedrock monitoring well data, included in the <br />October 16, 2012 submittal as Table 4.2iii will be removed from the permit. <br />12. DRMS: GW -10 was apparently added to the monitoring plan as reported in the <br />2011 AHR, but then removed at some point during the PR -2 review process. The <br />Division recently received an abandonment report for GW -10. The sealing of this well <br />should be added to the permit text at the top of page 2.04 -18 and to Figure 4.2 -2. <br />MCM: GW -10 has been sealed since the large coal mine waste disposal area is no <br />longer planned. Please see revised page 2.04 -18. See revised Figures 4.1 -7, 4.2 -2. <br />13. DRMS: On page 2.04 -18 MCM has proposed that monitoring well GW -3 will serve <br />as the point of compliance for the mining operations. Rule 4.05.13 requires that if the <br />point of compliance is not located in the permit area then other appropriate location <br />shall be agreed upon by the Division and the permittee. No point of compliance has <br />been proposed for bedrock groundwater. The Division would like to meet with the <br />Operator to discuss the need for points of compliance as suggested in Item 11 <br />above. <br />MCM: DRMS had a meeting with McClane Canyon Mining and JE Stover & Associates <br />on January 23, 2013. At the meeting it was agreed upon that GW -3 will serve as the <br />point of compliance for mining operations. <br />