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~ ~ r 2. The operator is proposing to conduct semi-annual monitoring and a full-suite annual sample in Naturita Creek. I propose that the Division approve this portion of the revision. (see ~5 below) 3. I would propose that the Division require a spring and seep survey in April or May of each year. For each spring which has measurable flow, field parameters be recorded. For each spring which is flowing greater than 5 gpm, the operator take a full-suite sample and also visit the spring again in the fall to record measurable flow and field parameters. In this case, this recommendation requires less monitoring than what the operator is proposing. 4. For the alluvial wells in Bramiers Draw and Naturita Creek, I would not recommend we accept the operators proposal. Both Naturita Creek wells show a markedly lower water level from the baseline values recorded. I would recommend that the operator monitor alluvial wells on a semi-annual basis for field parameters and take a fall full suite sample. 5. For those instances where the operator proposes an annual full suite sample, does the operator plan to take a sample at the first opportunity or collect the sample at a specific time of year? If specific, they should specify which visit they will be collecting or planning to collect a sample. 6. The situation with the bedrock wells is somewhat more troubling. Review of the baseline information available indicates a piezometric surface which was well above the completion depth of the three bedrock wells. However, this could not be determined accurately because the Division does not have completion information on file. This information was requested in a letter to David Andrews of Lillylands Coal Co. from the Division on January 6, 1988. Some generic information was received in August of 1988 but is not identifiable as specific to the three bedrock wells, BW-1, BW- 2, and BW-3. Regardless, if one assumes these wells were all completed in the water bearing zone, the following facts are noted: * Two of the three wells are represented as dry based on data collected in 1994. * based on information presented in the permit, the operator has and apparently continues to pump BW-1 and BW-3 for stock watering usage. * comparison of the 1994 data to the piezometric surface represented on the Hydrologic Area Map revised 7-13-92 clearly shows an impact to the Burro Canyon aquifer. * 5 springs, which are identified in the permit as emanating from the Burro Canyon aquifer, are also represented as dry