REV98610

• Permit No: C1982056
• IBM Index Class Name: Revision
• Doc Date: 10/19/1993
• Doc Name: LOWER TROUT CREEK SURFACE WATE STATION & ALLUVIAL WELL PN C-82-056 & C-81-071 DIV POSITION & RATIONA
• From: DMG
• To: TWENTYMILE COAL CO
• Type & Sequence: PR3
• Media Type: D
• Archive: No

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STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1317 Sherman St., Room 215
Denver, CO 80203
Phone: [phone]
FA%: (3031 832-8106
October 19, 1993
Mr. Marcus Middleton
Twentymile Coal Company
29587 Routt CR No. 27
Oak Creek, CO 80467
Re: Lower Trout Creek Surface Water Station and Alluvial Well
Permit No. C-82-056 (and No. C-81-071), Division Position and Rationale
Dear Mr. Middleton:
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Roy Romer
Governor
Michael B. Long
Division Director
Based on our conversation, I am providing you with this correspondence outlining the Division's
reasons requiring Twentymile Coal Company to establish a surface water monitoring site and an
alluvial well on Trout Creek below its confluence with Fish Creek. I will collectively address
Item Nos. 1 to 3 on page 4 of my 1992 AHR review letter dated August 27, 1993 for the
Eckman Park Mine.
As the Division's calculations show, mass salt loading to lower Trout Creek is 47 percent above
ambient conditions. This is above any past or present prediction. Additionally, much of the
permit PHC information is outdated, inaccurate and confusing. Twentymile Coal characterizes the
situation accurately on page 2.05-1181 of the Foidel Creek Mine permit (revised 5/22/86) where it
states, "no site-specific data are available for Trout Creek downstream from the Fish Creek
confluence to truly evaluate the calibration-versus-prediction water quality values based upon
upstream loads."
Rule 2.05.6(31(b)(iii) requires a "determination of the probable hydrologic consequences of the
proposed surface coal mining activities, or underground mining activities, on the proposed permit
and adjacent area," including "the effect the operation would have on concentrations of total
dissolved and total suspended solids, total iron, pH, total manganese and other parameters
required by the Division." Subpart (iv) then requires a "plan based on the probable hydrologic
consequences...to determine the impact on the hydrologic balance." It is no secret that the
greatest concern from mining at the Foidel Creek Mine and the Eckman Park complex is the
increase in salinity to lower Trout Creek. It only makes good sense to monitor Trout Creek to
establish a quantitative data base that can be used to verify predictions rather than using more
calculations to verify previous calculations.
Rule 4.05.13(2)(a) requires the monitoring program to be submitted and "approved by the
Division."
Recently, some preliminary discussions were held with regard to a potential reduction in
monitoring of the Eckman Park Mine due to its reclaimed and inactive status. It is appropriate to