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Requirement <br />Regulation <br />Reviewed <br />Comment <br />N. Timely filing of <br />CDRMS <br />pond reports <br />regulation <br />Yes <br />4.05. 9(17) <br />O. Content of pond <br />CDRMS <br />regulation <br />Yes <br />reports <br />4.05. 9(17) <br />Several issues were identified with the monitoring <br />frequency: <br />• For well J -1, water elevations table was not <br />submitted, Figure A -11 of Appendix A of the 2012 <br />P. Sampling <br />Table 4.8 -13a <br />AHR indicates this well is dry. However water <br />frequency of <br />of CDRMS <br />quality sampling data was submitted for this well. <br />groundwater <br />mining <br />Comment <br />It is unclear how a water sample could be taken if <br />monitoring wells <br />permit C -81- <br />the well was dry. <br />010 <br />• Ground water quality data was not submitted for <br />wells P -3 or P -5 for 2012. Data through June 2005 <br />and June 2011 was submitted for wells P -3 and P -5 <br />respectively. <br />Several issues were identified with the parameters <br />analyzed: <br />Table 4.8 -13 <br />• Manganese, aluminum and chromium were not <br />Q. Parameters to be <br />of CDRMS <br />reported for the 2nd quarter in accordance with the <br />analyzed in <br />mining <br />Comment <br />approved monitoring schedule for well GF -4. <br />groundwater <br />er <br />permit C -81- <br />p per <br />• Aluminum and chromium were not reported for <br />samples <br />the 2nd quarter in accordance with the approved <br />monitoring schedule for wells GF -5, GF -7 and <br />GMP -1. <br />Based on previous analysis by DRMS staff, the Third White <br />Sandstone aquifer is the only bedrock stratigraphic unit <br />having significant permeability that is in the groundwater <br />flow path of any coal spoil leachate; therefore, the Third <br />White Sandstone is the only bedrock stratigraphic unit whose <br />ground water quality may be negatively impacted by mining <br />at Trapper. Well GP -9 monitors the Third White Sandstone <br />immediately downgradient from Trapper's pits at a location <br />where a leachate plume can be expected to form, as <br />explained in the PHC (Section 4.83 of the permit). Well GP- <br />CWQCC <br />9 is Trapper's ground water point of compliance for the Third <br />R. Basic Standards <br />regulations <br />Comment <br />White Sandstone as explained on permit page 4 -242. In <br />for Ground Water <br />41.4 and 41.5 <br />general, the 2012 data from well GP -9 does not exceed Basic <br />Standards for Ground Water for a domestic use <br />classification. (This classification is for the Third White <br />Sandstone in a Specified Area that extends outward from <br />Trapper's northern permit boundary on the east half of the <br />mine to the axis of the Big Bottom Syncline, a distance <br />ranging between 1/2 and 314 mile from the boundary.) There <br />are exceedances of drinking water standards for Fe and Mn; <br />however, Fe and Mn exceedances also occurred in GP -9 <br />prior to mining in the area upgradient of this well. <br />Furthermore, other hydrogeologic and water quality factors <br />(e.g., concentrations of TDS and sulfate) indicate that coal <br />Page 4 <br />