2015-06-04_HYDROLOGY - C1994082 - Laserfiche WebLink

Home Browse Search

AN,COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 Eric Fry 1509 Glenmoor Rd Evansville, IN 47715 June 4, 2015 Re: Seneca HW (Permit No. C1982057); Yoast Mine (Permit No. C-1994-082) Hydrologic Monitoring Program Dear Mr. Fry, The Division received your informal enquiry as to the potential of reducing the groundwater monitoring programs at the Yoast and Seneca IIW mines. I reviewed the currently approved programs (which are found in Tab 15 of the respective permit application packets [1] and [2]), and offer my comments below. The water monitoring programs were pared back to the bare minimum in terms of locations and sampling frequency in 2010 (with TR47 at Yoast, and TR69 at Seneca IIW); any further reductions would require a technical revision, but do not appear to be viable from an initial review. Rather than invest undue time and effort pursuing this further, I would suggest that Seneca Coal Company consider an alternative course of action. Although it has been common practice for permitted coal mines to terminate water monitoring with final bond release, this is not required. It is not unprecedented for an operator to submit a technical revision requesting the termination of the water monitoring program prior to final bond release. In order for such an application to be successful the site would need to be "close" to a final bond release application, and be in compliance with the approved water monitoring plan at the time of the application. The application would also need to satisfy the criteria laid out in a Guideline Regarding Selected Coal Mine Bond Release Issues [3]. Part 1, section IV (A), item 5 of the guidance document is summarized as follows: The operator should provide a detailed analysis of the impacts to the quantity and quality of surface water and groundwater. The analysis should show that onsite impacts have been minimized and offsite impacts prevented, and should include: • an assessment of the available hydrologic data, relative to the impact projections contained within the approved Probable Hydrologic Consequences (PHC) and the applicable Cumulative Hydrologic Impact Assessment (CHIA); and • an evaluation of any impact trends which may exist in the available data pP CC310 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us John W. Hickenlooper, Governor I Mike King, Executive Director Virginia Brannon, Director