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i~ ,= • ~I I I I ~ I~~~ II~ 1990, 1991, AND 1992 AHR REVIEW WEST ELK MINE PERMIT NO. C-80-007 990 AND 1991 AHR REVIEW: 1. (#1, Groundwater) MCC has not been collecting data for wells SOM 38-H-2 and SOM 38-H-3 for the last few years because they were mined through and are no longer usable for the monitoring program. MCC has requested that the two wells be eliminated from the monitoring program. There are other wells in the ~„p~ same area as SOM 38-H-2 that monitor the same formation (the V~~ barren member above the F seam) and probably is okay to remove b~ .~, from the monitoring program and not replace. SOM-2 and SOM-16 t;~' `,`~~~ ~ kare completed in F seam as is SOM 38-H-3, but the two wells (~ ~~- ~~ are up-gradient of mining. Do we need a replacement well?_ \ \^4,1, ,\~\3~~ ~~a` in both cases MCC is proposing to temporarily seal the wells `,~ ~~1~ ~ so that they be used to monitor water levels in the mine ~~~(,'~ ~ workings and recovery of he p ezometric surface during '~ ~^ts~~\ ~ reclamation. I}aw r~l~ 11~.y t{o p,3 i~ 7u ..e~S ,ravc w~~.~ i„~.yl,•,.' ~\1~ 'U ~~l(;,x'~ Is it acceptable to eliminate both wS lls from the monitoring ~}-~ ~p \9~ ~ program without replacing them. Scc.~ Cu. y 5 s s Y 4 1~ C~. N N ~~_ ~' \~~ ~~~~,,f ~"~ ~7~~~~1992 AHR REVIEW ~~ ~r v > (#3, Surface Water) MCC is currently only taking a flow ~ .j ~^ measurement on the North Fork upstream of the mine. Quality ~ `^ ± ~ measurements are being taken at the same point upstream and a ~ -? point downstream. I have asked MCC to provide flow i 6 s ~ measurements for the downstream site as well. MCC has argued ~ -; ~ ~ that early in the monitoring program, it was determined that ~ ~ ~ only one flow station on the North Fork was necessary since•;'i .. the impact of the mine on river flows would be negligible. My = i3 reasoning was that you need quantity to evaluate quality. But ~ they argue that it is not economically feasible to establish '/'r; such a gage and that the monitoring plan was designed toy ~ r assume that the flows at the two sites were adequately similar ``~ c $ to allow the use of the upper station's flows at the lower ra, site. ~ ~ = ~ i .. Do we need flow measurements on the North Fork downstream qf: the mine site? ~ 2. (#1, Springs and #4 and #18, Groundwater) It was noted that MCC's permit required them to collect a second sample if indicator species falls outside its historic range. MCC was not doing this. The reason they have provided is that samples sent to the lab require 20-30 days to receive results and if