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~~ <br />•i <br />'I <br />• • <br />Ms. Christine Johnston <br />Mountain Coal Company <br />Page 3 <br />February 27, 1997 <br />5. The problem of missed analytical pazameters could be avoided by ensuring that chain-of- <br />custody documents are properly filled out for every sample shipment to the laboratory. <br />The Division recommends that chain-of-custody documents that accompany every <br />shipment of samples to the analytical laboratory include a complete list of the specific <br />analyses requested for each sample shipment. No further response is required. <br />6. As previously requested, please add anion and cation balances to the analytical program <br />for surface water samples. Please revise the permit document including Table 5 Water <br />Quality Water Monitoring Program to reflect this change. <br />7. The Division understands the methodology used to develop astage-discharge relationship, <br />and agrees that the most accurate method for determining stream discharge is by installing <br />a gaging station. The Division would recommend a continuous flow monitoring station <br />similaz to the upstream USGS station. The Division agrees that this would be a costly <br />project in terms of capital investment and permitting effort. For this reason, the Division <br />is recorrtmending that MCC continue to focus on the current monitoring program <br />including: continuous flow data for the USGS upstream station, accurate measurement of <br />water usage from the North Fork Gunnison River, CDPS discharge volumes from on-site <br />ponds, discharge of mine inflow water, and all water quality analyses including instream <br />samples and those associated with various discharges. Stream gaging at a location <br />downstream from the mine site is considered a useful tool for quantifying water quantity <br />impacts and may be useful for determining water quality impacts with respect to mass <br />loading of potential contaminants. A downstream gage may be deemed necessary and <br />appropriate in the future. No further response is required from MCC at this time. <br />The minor revision application submitted will be considered complete and adequate upon receipt <br />of the above information. Thank you for your cooperation. <br />Please call if you have any questions. <br />Sincerely, <br />M~~ ~~~-/ <br />Michael P. Boulay <br />Environmental Protection Specialist <br />c: David Berry <br />