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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. This report will summarize observations made by the Office of Surface Mining (OSM) and the Division of Minerals and Geology (DMG) during an OSM surface water hydrology special focus inspection at the West Elk Mine. OSM hydrologist Joe Wilcox and DMG inspectors David Berry and Mike Boulay reviewed laboratory analytical data and inspected various surface water hydrologic features at the mine site on October 17, 1996. Mountain Coal Company (MCC) personnel Christine Johnston and Henry Barbe accompanied the OSM and DMG during the entire inspection. Kathy Welt of MCC was present during the laboratory data review and discussion, and the wrap-up meeting following the site visit. An overview of the site visit and specific issues/recommendations identified during the inspection are discussed below. Overview of Site Visit Prior to the on-site inspection, Joe Wilcox reviewed the West Elk Mine permit document, the 1995 Annual Hydrology Report (AHR), and the DMG's adequacy review letter for the 1995 AHR. At the mine site, Mr. Wilcox reviewed laboratory analytical data reports for surface water monitoring occurring in Water Year 1995 and the associated chain-of-custody documentation. Surface water features inspected "on the ground" included surface water ponds and their respective Colorado Discharge Permit System (CDPS) discharge points including: Pond MB-1/outfall 002, Pond FW-1/outfall 006, Pond MB-2R/outfall 004, Pond MB-3/outfall 005, Pond MB-4/outfall 008. Other surface water features inspected include: North Fork Gunnison River Upper (USGS N. Fork gunnison Gage near Somerset), North Fork Gunnison River Lower (N. Fork Gunnison below mine), Lower Sylvester Gulch, Spring G-13 in Sylvester Gulch, and exploration drill hole locations RAV-4 and R-ALT. Drill hole RAV-4 has been converted to a groundwater monitoring well. Conclusions and Recommendations Based on the site visit, the OSM and DMG make the following recommendations in an effort to minimize potential off-site impacts and to improve the current surface water hydrology monitoring program at the West Elk Mine. (1) As a quality assurance/quality control check on the laboratory analytical data, add anion and cation balances to the analytical program for surface water samples. (2) The chain-of-custody documents that accompany every shipment of samples to the analytical laboratory should include a complete list of the specific analyses requested for each sample shipment. It was noted that several of the chain-of-custody documents reviewed did not have a listing of the requested analyses, and in some instances did not correlate well with the laboratory data reports that they were attached to. 1