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<br />limitations in today's labs. The applicant should investigate and address this issue of <br />lower detection limits. <br />Selenium <br />The DOW recommends including selenium in the normal sampling program due to <br />potential and existing concems in the Aiicansas River basin. The Division concurs and <br />requests that the applicant include selenium in the surface water monitoring list. <br />Iron levels in the Pur ag toire <br />The DOW has noted that iron levels during low flow in the Purgatoire River aze projected <br />to exceed water quality standazd 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 dischazge 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 compazing actual data <br />to predicted water quality for all sampled pazameters. The Division considers this issue <br />adequately addressed. <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 ::istwbed lands on the site. The DOW indicates <br />concems over the degree to which the applicant plans to contain sediment at the site. <br />Appazently, the DOW believes that mines in the past have had to retain the flow from a <br />100-yeaz 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 runoff from a 10 yeaz, 24-hr storm event. <br />For this mine, due to the large size of a number of the ponds, they will also be required <br />to "safely pass" the runoff from a 100-yeaz, 24-hour storm event. The Division has spent <br />considerable time reviewing sediment pond design and adequacy issues remain to be <br />reviewed at this time. However, the Division will not require the applicant to contain <br />surface water flows. Dischazge limitations will apply at this site, as they do at all coal <br />mines in the state as required by the Clean Water Act and other State and Federal laws. <br />Haul road runoff will be treated by using alternative sediment control practices. (see <br />Reduction of stream crossines above) <br />The Division considers this issue to have been adequately addressed <br />Freauencv of monitoring <br />