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Mr. Michael R. Neumann October I5, 1997 Page 2 3. The Division has the following question regarding how data are reported. Concentrations of some parameters were reported in 1996 as "total recoverable", or in some cases "dissolved", in contrast to past years' reports which had no such annotations. Are the annotated values directly compazable to figures not annotated in prior years? Water quality exceedances The water monitoring data in the report and the NPDES Discharge Monitoring Reports indicate that no water compliance limitations were exceeded. Surface water quality -Ponds 003 and HG-8 All water flowing on the ground surface (rtutoff, effluent from seeps and springs) in the permit area is routed through ponds 003 and HG-8 and then flows into the stream channel of Hayden Gulch which lies on the east side of County Road 53. Hayden Gulch flows southwest to the Williams Fork River drainage. (Ponds 001 and 002 were reclaimed in October 1996.) There were no exceedances of the ponds' dscharge limitations in 1996. There is a strong contrast between the chemical composition of water from pond HG-8 compared to pond 003. Pond HG-8 collects water from the mined-out pit area and the excess spoils pile. Spoil springs and seeps feed HG-8. Consequently, the water is very hazd (more than 700 mg/1 of calcium carbonate) and is high in total dissolved solids (greater than 2,000 mg/1). The high sulfate content in 1996 (greater than 1300 mg/I) is characteristic of the oxidation. of sulfur minerals (gypsum and/or iron sulfides) in coal spoils. In contrast, surface water from the west side of the road in pond 003 originates from surface runoff from disturbed (but untrained) ground and one natural bedrock seep. The water is relatively soft (less than 200 mg/1 of calcium carbonate) and it is low in total dissolved solids (less than 300 mg/l). The sulfate content was very low in 1996 at 40 mg/l. Water from pond 003 is suitable for agricultural use, but water from pond HG-8 appears to be too high in sodium and sulfate for such use, which leads to the following question. 4. Section 2.05.5 of the pettnit designates livestock grazing and wildlife habitat as the post- . mining land uses of the H-G mine site. Section 2.0.4(1) of the permit says that pond HG-8 is a permanent impoundment that will provide a source of water for livestock. Given the pond's current high sodium and sulfate levels, please explain how pond HG-8 can be used as a source of water for livestock. Surface water quality -UHG-l The chemical compositions of waters from the upstream surface water monitoring site, UHG-1, have fluctuated within a narrow range since monitoring began in 1987. No trends in composition upward or downward are evident. The water is suitable for agricultural use and possibly for drinking water.