REV90363

• Permit No: C1981008
• IBM Index Class Name: Revision
• Doc Date: 1/26/1993
• Doc Name: GROUND WATER REVIEW MEMO
• From: CATHY BEGEJ
• To: HARRY RANNEY
• Type & Sequence: RN2
• Media Type: D
• Archive: No

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`~~ STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depanmen(o( Natural Resources
131 }Sherman SI., Room 215
Denver, CO 80203
Phone: [phone]
FAX: [phone]
DATE: January 26, 1993
TO: Harry Ranney
FROM: Cathy Begej C"-
RE: Ground Water Review, New Horizon Permit Renewal, C-81-008
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Roy Romer
Governor
Michael 8. Long
Dmicion Direaur
I have serious problems with the New Horizon Mine Permit Renewal organization as I
understand it. Western Fuels Colorado submitted two volumes of narratives and maps to
supersede the information on Nucla East in the existing fourteen volume document. The
permit renewal volumes specifically identify portions of the previous document for
inclusion. This can only lead to confusion for both the operator and the Division. This
configuration ignores a substantial amount of excellent work performed by Peabody.
Please note that I found references to Nucla's New Horizon's hydrology in the information
found in the new permit volumes. Additionally, it results in a sixteen volume permit
application instead of a fourteen volume mining and reclamation plan.
To underscore my point, I would like to give a specific example of the impact of this
configuration on the ground water portion of the permit. The proposed permit renewal
configuration incorporates Appendix 7-1, Figure 7-1 , Appendices 15-2 and 9-X, Volume 3,
Tab 15, Attachment 16-1, Tables 7-32A and 7-32B, Table 9 of attachment 16-1, and
portions of Tab 17. Western Fuels-Colorado appears to have re-worked the narrative
found originally in Hydrology Tabs 7, 15, 16 and 17. However, they did not incorporate
the baseline water quality data, any comparisons of water quality with state and federal
water quality standards, aquifer test data used to describe physical characteristics of the
aquifers, completion diagram documentation, ground water chemistry and detailed
information on the water quality portion of the probable hydrologic consequences section.
Please see the attached tables of contents and note the areas that are specifically
deficient.
1) Please incorporate all baseline hydrology data into the revised permit. Include
baseline water level and water quality information. The Division is interested in
reviewing data acquired from all individual sampling dates as well as generalized
reductions of that data, i.e. well hydrographs, and graphic representations of
sample geochemistry, The original permit included data acquired between 7/86 and
11/87. Include the data acquired between 11/87 and 9/90 (Rule 2.04.7(1)1.
2) The narrative describing the baseline data should incorporate references to
proposed water quality criteria for varying uses (Rules 2.05.6(3)(bllii) and
4.05.2(7)).