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December 30, 2015 <br />CDS Tom Bird Sent via email to tbird(a)gcc.com <br />Manager of Coal Services <br />Environmental Services GCC Energy, LLC <br />6473 County Road 120 <br />Hesperus, CO 81326 <br />Environmental Chemistry RE: Review of Annual Hydrology Report <br />Dear Mr. Bird, <br />Site Sampling & Testing As per your request, Dr. Joe Bowden of our office reviewed <br />the 2015 water sampling data from both the King I and the King II <br />mines monitoring wells/sites. This review is to address any <br />Site assessments changes in trends and/or areas of concern, which are evident <br />from an analysis/interpretation of the presented data. <br />Our new office is located at 801 Perins Canyon Drive - Our local phone is still 247-0132 <br />The information submitted with this report updates previous <br />Strategic Planning <br />monitoring data delivered to the State of Colorado, Division of <br />Reclamation, Mining and Safety. As noted in our 2014 report the <br />trends, in most cases, are still represented by analytical values <br />Soil & Geochemistry <br />with high degrees of variability. Also, as noted in the 2014 report, <br />most of the trends remain flat and continue to exhibit large <br />standard deviations. Nevertheless, it is our professional opinion <br />Saiccy vs<, „, ,a <br />that many of the trends noted in our 2014 report are real as noted <br />below. The two following paragraphs were extracted from that <br />report and remain valid for 2015. <br />Cun: race Research <br />As to the question are these trends a result of the mining activities at either <br />King I or King 11, it is again our professional opinion that these trends are not a <br />result of mining activities at either King I or King 11 mines. The single constant <br />Wctiand Ren,ediar.ion <br />observation over the monitoring cycles is a very high degree of analytical <br />variability which tends to follow the dry/wet cycles of precipitation observed in <br />Southwest Colorado. Some of these cycles are profound in their degree of <br />variability. For example, the water levels measured in the King 11 Down -gradient <br />R lan-tion Servi< <br />monitoring well varied from near artesian [2 inches below top of well] to a depth <br />of more than 110 inches below top of well. <br />The southwest setting of these mines are at the interface of two regional <br />..............................•••• <br />environs, the northern edge of the high desertlpinon-juniper ecosystems, and <br />southern edge of the low alpine/Gambel Oak -Ponderosa Pine zone. This interface is <br />P . o . sox 4 f 2 4 <br />noted for unpredictable precipitation events, driven by decade long regional <br />Durango, CO 81302 <br />warming and cooling cycles. For example, the annual rainfall for three nearby <br />1 8 0 0 s s 3- 6 2 6 6 <br />towns, demonstrate this unpredictable nature. Durango, CO has a ten-year <br />average rainfall of around 21 inches, Cortez, CO comes in at around 12 inches, <br />cdsenviro(a,frontier. net <br />while Farmington, NM is only about 9 inches. The current weather cycle is in a <br />""""""".."."""""""' <br />warming phase. With this trend increased evaporation rates coupled with <br />reduced precipitation can produce upward trends in the concentration of <br />selected analytes due to a simple reduction in supplies of water. <br />Our new office is located at 801 Perins Canyon Drive - Our local phone is still 247-0132 <br />