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Carl 8 Mount, 6175 W Ohio Ave, Lakewood, CO 80226 <br />(GAROGuide). Availableav h t t rd nrn 1�'! F-�:, zjh,? a rite t 4and <br />5 <br />The GARD Guide is an industry written and accepted guide for identification, characterization, <br />prediction, and control of mine waste effluents. Chapters 4 and 5 specifically address mining waste and <br />the present state of the art for characterization of said waste and prevention (mitigation) of the effects <br />of those wastes on human health and the environment. it addresses not only acid mine drainage but <br />also neutral and saline drainage. <br />In addition, I have spoken with Mr. Randolph C. Fischer, P.E. (hydrology consultant), Mr. Dan Hernandez, <br />Senior Environmental Protection Specialist with DRMS and Ms. Robin Reilley, DRMS. <br />Background <br />An unpermitted waste disposal pile on the West Bench of the King I portal was the subject of DRMS <br />enforcement action CV2012003. The Notice of Violation was written in response to conditions observed <br />by a DRMS inspector on March 21, 2012. The violation file noted that GCC was disposing of Coal Mine <br />Waste not only in violation of the performance standards of Coal Regulation Sections 4.09.1, 4.09.2, <br />4.10 and 4.11 but also in a place that had not been permitted for waste disposal (the West Portal Bench <br />of the King I Mine). As part of the corrective actions required by DRMS, GCC subsequently removed that <br />waste and deposited it in the permitted waste disposal pile that was used for King I Mine waste. <br />It should be noted that the regulations cited under violation CV2012003 specifically require designs for <br />waste piles to minimize the adverse effects of leachate and surface water runoff from the waste <br />material on surface and ground waters and require the operator to comply with the effluent limitations <br />of 4.05.2 with regards to surface water. <br />It should also be noted that the La Plata County code at Section 82-193(c)(2) states, in part, "A <br />compatible development is one which will meet all of the following standards: ...c. The development <br />will not cause pollution of ground or surface waters..." and, under Section 82-192. — Mitigation <br />measures. 'To gain a determination that development is compatible, the applicant shall be required to <br />take all necessary mitigation measures to achieve compatibility with existing, adjoining land uses as <br />outlined in this subcategory." I am not aware of any monitoring data or any other data that would allow <br />La Plata County to make these determinations at this site. <br />The February 8, 2016 article from the Durango Herald newspaper reporting on GCC Energy's Toxics <br />Release inventory (TRI) and subsequent searching of the TRI database indicated that GCC had released <br />742 pounds of lead compounds and 4.99 pounds of mercury compounds in 2014 (see <br />"facts ri"'of <br />The United States Geologic Survey (USGS) took samples from many water sources in the area in 1983 <br />and noted lead, cadmium, and fluoride in elevated levels that exceed Primary Maximum Contaminant <br />Levels at the Wiltse Well, an alluvial groundwater well in Hay Gulch directly downstream of the present <br />waste pile (Brooks, 1985 available at httu'-//pub. usgs.-ov." Secondary <br />Maximum Contaminant Levels of manganese, sulfate, and total dissolved solids were also exceeded at <br />this well. The Brooks paper states: "in conclusion, it is important to monitor changes and to describe <br />the hydrologic systems prior to large-scale mining so that future mining impacts may be assessed." <br />Mt. Luke Danielson, Lsq. <br />Xing I and 11 WL, Wati%r and C -o-31 Mine Miv,,, Cnncsvns <br />May 11, 2016 <br />