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;~~ °- Mountain Coal Company West Elk Mine Past Office Boz 597 Somerset, Cokxado 81434 Telephone 970 9?&5015 Fax 970 9?9.5595 September 19, 1996 Mr. Michael 13oulay Colorado Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, CO 80203 n~_i.~'I~,l III IIIIIIIIIIIII III SEN L 3 1996' ` Dc~i,iun ut rvunGius G C+OOIOOy ' 1ZE: lnventoried Stockpouds oo Jumbo Mountain; West Elk Mine; Permit No. C-80-007 Dear Mr. Boulay: Mountain Coal Company (MCC) bas received a letter from the Division dated August 22, 1996, requesting a letter verifying the station number and current monitoring procedures for the "reservoir" located on the Mautz property and a minor revision to amend Table 5 with water level measurements of the reservoir. The Division's letter of August 22, 1996 requested verification of the identification of the "reservoir" visited during the July 24, 1996 inspection. As shown an the map "Jumbo Mountain Panels and Landslide Area" previously sent to the Division under separate cover (hand delivered on August 26), the stockpond visited is shown as Location #6, as identified in the Division's inspection report, and is known as the Wilcox Reservoir. This pond is shown as Resource #14 on Map 37 and is identified as monitoring location #6 on Map 34. The Dames associated with this resource are cross-referenced in Table 5, page 2.0453. Please note that this pond is located outside MCC's permit boundary, and is therefore, outside of the expected angle of influence from mining. Wilcox Reservoir No. 1, located south of Wilcox Reservoir, is within the permit area. This stockpond is also shown on the above referenced map sent to the Division under separate cover. This slockpond is shown as Resource #16 on Map 37 and is identified as monitoring location #5 on Map 34. The names associated with this resource are also cross-referenced on Table 5, page 2.0453. These resources, as well as the other resources on Jumbo Mountain, were inventoried during We collection of baseline data in 1993 and have been monitored since that time. MCC believes that the collection of water level in stockponds would not yield any meazringfiil data and requests that the Division reconsider its revision request. As is the case with the above mentioned resources, these stockponds are not maintained and have filled (or are filling) or have been breached. Most stackponds are shallow and are fed by snowmelt runoff or springs. Changes in water level could vary widely from natural events, such as rainfall, drought or animal use. MCC believes that impacts from mining would not be accurately measured by water level, but rather by monitoring the inflow and/or outflow of these resources. Page 2.0458 of MCC's permit states the method in which reservoirs and slockponds are monitored As with Minnesota Reservoir, which is a considerably larger swcture than the subject "reservoirs', the inflow and/or outflow, if arty, of the slackponds are measured. In addition, MCC monitors stockponds as described in the letter contained in Exhibit 19C. Although this letter specifically references USFS s[ackponds, MCC monitors all s[ackponds in this manner. In addition, MCC's monitoring contractor typically makes notes on the condition of the stockponds while collecting the water quality aM flow information. The flow and quality information of the stackponds is available in the Annual Hydrology Reports and comments on the condition of arty stockpond, if not in the AHR are contained within MCC's 51es, which are available for the Division's review.