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-2- <br />Decision to Require Revision <br />The Division has conducted a mid-term review under Rules 2.08.3, <br />2.06.2(a), 2.06.3(4), 2.06.5(3), 2.06.7(5) and 3.02.2(4). The Division finds <br />that certain revisions and modifications are needed to ensure future <br />compliance with the Colorado Surface Coal Mining Reclamation Act and the <br />Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. The <br />following section details the revisions required and a justification for <br />requiring the revisions. Section IA responses should be submitted as a <br />request for revisions by September 1, 1988. <br />Hydrology <br />The Division reviewed past water quality monitoring data collected at the mine <br />site over the past several years. Some of this data had been collected by the <br />operator and the rest was collected by the Division. The water quality data <br />was compared with the statement of probable hydrologic consequences outlined <br />in the permit application. The review indicated that the permit application <br />did not sufficiently address the problem of acid mine drainage at the mine. <br />Observation and water monitoring by the Division has shown sources of acid <br />mine drainage that were not predicted in the application. The application <br />only addressed acid discharge from the pipe extending out of the abandoned <br />workings of the Victory No. 1 Mine. Although acid discharge from this pipe <br />has almost ceased this year (1988) the sediment pond below the disturbed area <br />has had problems with acidity. Sampling of this pond in October, 1987 and in <br />March, 1988 showed pH values around 3. Seeps flowing from around the coal <br />stockpile had pH values as low as 2.1. From these observations it appears <br />that there are acid forming materials at the mine that need to be addressed, <br />in terms of treatment, disposal, handling, and reclamation. <br />Pages 2.04-15B and 4.05-7 state that "Acid-forming and toxic-fo rniing materials <br />do not exist at the Coal Gulch Coal Mine". From the observations and sampling <br />conducted by the Division it appears that the Coal Gulch Mine does have acid <br />mine drainage. Not only is it associated with the past disturbances from <br />coal mining but with the current mine also. The permit application contained <br />chemical analysis of the roof, coal and floor material. (Table 2). The floor <br />analysis indicates that there is enough pyrite (3.2~) to be potentially acid <br />forming, also the pH of the sample was 5.3 indicating that oxidation of the <br />pyrite has already begun to occur. The permittee will need to address the <br />problems with the acid-forming floor. <br />For these reasons the Division is requiring that the Coal Gulch Mine submit a <br />revision which specifies the following: <br />The operator or permittee will submit to the Division within one year of <br />portal establishment a report containing the following information. <br />An analysis of 3 separate coal, roof and floor samples taken at various <br />distances from the portal. The sample will be analyzed for the net acid <br />production potential using the Acid/Base account method developed by <br />Dr. R. M. Smith and coworkers at West Virginia University. <br />B. Underground seep monitoring will be conducted. All seeps will be located <br />on the mine plan map. The source of the seep (whether roof, coal seam or <br />