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• Division of Wildlife Issues and Responses <br />for June 5, 1997 Letter <br />(continued) <br />Selenium <br />The DOW recommends including selenium in the normal sampling program due to <br />potential and existing concerns in the Arkansas River basin. The Division concurs and <br />requests that the applicant include selenium in the surface water monitoring list. <br />Response <br />LCC has revised Table 2.05.6-10 on page 2.05-106 to include dissolved selenium on the surface <br />water monitoring parameter list. <br />Iron levels in the ]?urgatoire <br />The DOW has noted that iron levels during low flow in the 1?urgatoire River are projected <br />to exceed water quality standard for that reach of stream. No comments were received <br />from the Water Quality Control Division by the Division. However, it is our <br />understanding that effluent limitations incorporated into LCC's discharge permit will <br />• consider iron loading to this stream reach and set effluent limitations accordingly. <br />Furthermore, the Division reviews the hydrologic reports annually for any evidence of <br />material damage to the hydrologic system. This review includes comparing actual data to <br />predicted water quality for all sampled parameters. The Division considers this issue <br />adequately addressed. <br />Response <br />No response is necessary for this comment. <br />Increased sedimentation <br />The DOW believes that the most significant issue to the fishery of Lorencito Canyon and <br />the Purgatoire River is increased sedimentation. They cite two sources of sediment <br />generation, haul roads and the remaining disturbed lands on the site. The DOW indicates <br />concerns over the degree to which the applicant plans to contain sediment at the site. <br />Apparently, the DOW believes that mines in the past have had to retain the flow from a <br />100-year event. <br />The Coal Rules do not require the applicant "contain" any size event. They do however, <br />require sediment ponds to "contain or treat" the tvnoff from a 10 year, 24-hr storm event. <br />• For this mine, due to the large size and number of the ponds, they will also be required to <br />"safely pass" the runoff from a 100-year, 24-hour storm event. The Division has spent <br />considerable time reviewing sediment pond design and adequacy issues remain to be <br />8 <br />