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.~ ~. 0 o III 010010~1~~~~~ DID 999 l~ '~~ Colorado Yampa Coal Company I 29588 Routt County Road #27, Oak Creek. CO 80467 • (303) 879-3800 November 19, 1985 Mr. Robert J. Shukle Industrial Unit Chief Permits and Enforcement Section Water Quality Control Division Colorado Department of Health 4210 East 11th Avenue Denver, Colorado 80220 ~a`~~ NOV 2 51985 CGft7. (1tl~1. of 1Y ::'Gi 3i ht:lY U1L~r Re: Amendment to CDPS Permit No. CO-0027154 Dear Mr. Shukle: As we discussed in our meeting yesterday, several spoil springs have developed in regraded mine spoil upstream from Pond A and outfall 001. As you are aware, this condition was not anticipated in our previous discharge permit nor in our Mining and Reclamation Plan submitted to the Colorado Mined Land Reclamation Division and Office of Surface Mining. Colorado Yampa Coal Company (CYCC) believes it is noteworthy to point out in the 1976 Northwest Colorado Coal Final Environmental Statement - Site Specific Analysis of the Energy Mine on page E11-7, that the USGS and BLM discussed the recharge characteristics of the Energy Mine spoils and concluded that "spoils appear to be less permeable than unmined ground, and hence may serve as a dam to prevent movement of groundwater to the stream." The report also stated that the dis- charge of waters from these mine spoils "would have only a 'negligible' effect on the water quality in the stream." It is unfortunate that the scientific expertise in the various government agencies (including CYCC) missed the mark in their predicting spoils water flow characteristics but, we feel obligated to point out that if errors were made, CYCC was guilty of making the same assumptions used by others. As we explained in our meeting, the exact number of springs and quanti- ties and qualities of waters are presently unknown. Due to our winter snow cover, it is impossible to complete an inventory until next spring. In this light we will be completing a survey to satisfy both CMLRD and CDOH concerns. The survey will consist of an intensive survey completed by the end of April, 1986. A proposed monitoring plan will be jointly submitted to the CMLRD and CDOH by the middle of May. Shortly after the receipt of this letter, CYCC will discuss the proposal with both agencies and implement a monitoring pro- gram. The monitoring program will be installed in the field by the end of June. Results obtained from the spoil spring monitoring will be reported to the CMLRD and CDOH.