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Richard D. Lamm <br />Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />Davitl H. Getches, Executive Director <br />MINED LAND RECLAMATION DI\ <br />DAVID C. SHELTON, Director <br />DATE: November 18, 1983 <br />T0: Fred Banta <br />FROM: Roy L. Cox <br />~,~~ <br />RE: Response to CF&I Letter Dated April 27, 1982, from <br />Jack D. Gillespie, File No. C-O12-81 and C-013-81 <br />The following discussion is a belated response to a letter from <br />Jack Gillespie to CF&I dated April 27, 1982. I have proceeded my <br />response with a historical prospective. <br />On July 20, 1981, Susan Mowry and I met with Dave Zeeb and Jack Gillespie <br />to discuss reduction in hydrologic monitoring at the CF&I's Allen and <br />Maxwell Mines. At the meeting with CF&I, the company proposed their <br />reduced monitoring plan to the Division. At that meeting all parties <br />agreed on the existing monitoring site at which continued monitoring <br />should take place. I did not agree with the water quality monitoring <br />proposed. The company wanted to only monitor field water quality <br />parameters of pH and electro-conductivity. I stated that the salt loads <br />(ionic balance) at a minimum should be analyzed and that I would have to <br />do an analysis of all the overburden and water quality data prior to <br />dropping out all trace metals. No verbal agreement was made as to the <br />parameters to be monitored. <br />On October 8, 1981, Mined Land Reclamation Division (MLRD) visited the <br />Maxwell and Allen Mines. The monitoring sites were shown to the MLRD <br />staff and the company's proposed monitoring scheme was reinterated. No <br />verbal agreement was made by me on the parameters to be monitored. <br />For the first draft findings, I reviewed the hydrologic monitoring plan <br />for Dave Craig and Jerry Zimpfer. This included a review of all <br />overburden (coal, roof, floor, and refuse pile materials) and surface and <br />ground water chemistry data. The overburden data were analyzed for the <br />occurrance and concentration of each chemical parameter. The overburden <br />analyses were then compared with the water quality analyses. <br />On April 1, 1982, I contacted the Colorado Department of Health to find <br />out if receiving stream standards had been established for the Purgatoire <br />River. I requested a copy of the promulgated proposed standards. I <br />received a copy of the standards on April 3, 1982. After receiving these <br />standards, I prepared a list of water quality parameters by eliminating <br />those constituents which were not considered suspect in my analysis of <br />the overburden and water quality data. The reasoning for requiring the <br />monitoring for receiving stream standards are described in detail in the <br />following paragraphs. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />