2024-05-03_PERMIT FILE - C1980007 (2)

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2.05-73 Rev. 11/96- PR07; 04/06-PR10; 12/14- TR136, 04/24 – TR153 TSS, pH, conductivity and iron (dissolved and total). A seasonal, rather than quarterly or semi- annual water quality monitoring schedule was instituted for a variety of reasons. The primary reason for selecting seasonal sampling is that, in many instances, particularly streamflow and spring flows, these are the only periods of measurable flow. Most of the streams are ephemeral or intermittent at best, and nearly all of the springs are ephemeral except in the wettest years. The baseline data clearly indicate that there is no reason to attempt to sample these locations during winter. The adverse conditions encountered in the remote areas of the West Elk Mine lease area severely hamper sampling procedures and influence the collection of meaningful data. As a result, by restricting sampling to the periods of flow and ensuring sample integrity, Mountain Coal Company will be able to provide meaningful data to the agency while reducing the costs associated with collecting unnecessary data or data that is not meaningful. Mountain Coal Company has selected the water quality parameters in Table 5 for routine measure- ment because they will adequately characterize the quality of the water. Annual full-suite monitoring (and the reduced parameter list) will allow Mountain Coal Company to identify possible mining-induced changes in water quality. West Elk Mine, in cooperation with the U.S. Forest Service District Office in Paonia, Colorado, has agreed to informally monitor the U.S. Forest Service surface water resources, as depicted on the U.S. Forest Service Water Resources Map, that are located directly over panels to be mined, and within the angle-of-draw per the agreement letter in Exhibit 19C. Spring Monitoring In 1977 Mountain Coal Company began a spring water monitoring program that incorporated monthly, quarterly and semi-annual monitoring of flow and/or water quality. Map 37 shows the springs identified on the West Elk Mine lease area, the monitored springs, the springs sampled for water quality, and the locations of the decreed springs on the West Elk Mine lease area and vicinity. Map 34 shows the location of springs currently in the monitoring program. The most recent Annual Hydrology Report provides a graphic representation of the flow data available for the springs monitored and water quality data. It is estimated that it might be some time before secondary recovery mining will take place south of the Minnesota Creek watershed divide. As a result, there is no need to operate and maintain the entire spring monitoring network until mining advances to a point where a specific spring might be impacted. Rather, monitoring of some of the springs will be stopped until the summer before mining impacts can be expected, at which time monitoring of appropriate springs will be resumed. Monitoring will continue, on a seasonal basis, for the springs in the approved monitoring program as listed on Table 5. In the Minnesota Creek drainage basin, monitoring was discontinued for springs J-4, J-7, J-10 and WCC-23 until the summer before mining impacts can be expected, at which time monitoring of these springs will be resumed. Monitoring of spring J-4 was reinitiated in 1996. Monitoring of a group of three springs (G-25, G-28a and G-31) in Gribble Gulch and one spring (G-26a) in Lone Pine Gulch were discontinued for several years due to access being blocked by landslides. The monitoring of spring G-26a in Lone Pine Gulch, spring G-25 (#15, Jumbo Spring No. 2 Pond) and spring G-31 (#18, Jumbo Mountain Spring No. 4 Pond) were resumed in 1993. Spring G-28a was