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2. Surface Water Hydrology Ditch PD-4 had been maintained to drain positively. C. Review of Surface Water and Groundwater Monitoring Da[a 1. Surface Water Runoff from Pit 1 is directed to flow to Ponds E and F. Dischazge monitoring records for these two ponds in the 1992, 1993, and 1994 Annual Hydrology Reports document that Pond E was observed by Kerr personnel to be dischazging three times in 1992, five times in 1993, and twice in 1994. Pond F was observed to be discharging three times in 1992, four times in 1993, aml twice in 1994. The 1995 Annual Hydrology Report had not yet been submitted to DMG at the time of this report. During 1992, 1993, and 1994, records indicate that the quality of the water dischazging from these ponds at times exceeded certain effluent limitations imposed at pond outfalls under the Colorado Pollutant Discharge System (CPDS) Permit issued to Kerr Coal Company by the Water Quality Control Division of the Colorado Department of Health and the Environment. Records indicate that Kerr Coal Company addressed these problems to the satisfaction of the Water Quality Control Division without fotmal enforcement actions being taken. DMG personnel contacted personnel from the Water Quality Control Division in January 1996 with regazd to the status of Kerr Coal's compliance with its CPDS permit for calendar year 1995. A representative from the Water Quality Control Division informed the Division that Kerr Coal was in compliance during 1995 as well. As the spring of 1996 will be the first high surface water runoff period since the backfilling of both the 720 Pit and Pit 1, TSS (total suspended solids) levels could exceed CPDS limits at pond outflows this year. Kerr Coal Company will need to continue to be diligent in maintaining rills and gullies in the reclaimed areas and in maintaining all sediment collection ditches and pond inslopes to minimize soil erosion, and associated increases in solids levels, whenever possible. Kerr will also continue to be required to report any such exccedences to the Water Quality Control Division, to remain in compliance with the terms of the CPDS permit. 2. Ground Water There are no groundwaters in Jackson County that have been classified for a particulaz use by the Colorado Water Quality Control Commission. Consequently, no specific water quality standards for any particular use have to date been established in the county. Determination by DMG as to whether groundwater pollution is occurring is therefore herein based upon comparisons of 1982 baseline groundwater quality, the expected impacts to groundwater quality as described in Kerr Coal Company's description of Probable Hydrologic Consequences, and -5-