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iii iiniiiiniu iii a99 STATE OF COLORADO MINED LAND RECLAMATION DIVISION oF; ~~o Department o1 Natural Resources Nti j4yg 7373 Sherman St., Room 2t5 ~-r Denver, CO 80203 ' "~~; 303 8663567 ' raja Fgx:303 832-8706 Roy Raner. Gavemor p Fred R. Banta. A ril 24, 1991 Divieion Director hlr, Steve Sel f Eastside Coal Inc. P.O. Box 161 Silt, Coloraao 81652 RE: Eastside Mine (Permit C-84-063) Establishment of Points of Compliance and Implementation of Senate Bill 131 Dear Mr, Self: I would copy and send to you as a result to our recent telephone conversation. These standards were most recently revised in late 1989 and would eventually be utilized by the Division, as an implementing agency under SB 781, to set the ground water standards applicaole at points of compliance, once such points were established. As I mentioned, if there was disagreement bettiaeen the Division and the mine/operator over the suitability of the standards selected, the Water Quality Controi Commission could be petitioned to classify and promulgate water quality standards in regard to the water in question, Enclosed is a copy of the "Basic Standaras for Ground Water" which I indicated As indicated in our conversation, revision of the regulations under which the coal program functions to require the establishment of points of compliance for all operations under its jurisdiction will take sane months to work through the approval process by OSM and EPA. Once approved, individual mines would then be dealt with individually, so far as establishing points of compliance and monitoring for compliance, at times of permit renewal or mid- term reviews, As far as the problem you mentioned as concerning you most, i.e., being required to establish a point of compliance for a bedrock aquifer down dip which might involve drilling a deep (because of steep dip) monitoring well, adverse effects to a bedrock aquifer must be indicated to begin with in order to require a point of compliance. It is also possible, since economic reasonableness is a consideration in the Water Quality Control Commission determinations of "less stringent" points of compliance (see page 16), that such a consideration can be made by the Givision. Possibly a "point of compliance" might also be based on modeling of the hydrologic circu instances with any actual monitoring done at closer, shallower or existing monitoring points to support the validity of the model and to demonstrate compliance with water quality standards at the point of compliance itself, where no actual well or monitoring might exist. This last proposal was suggested by industry representatives as a possible approach to eliminate additinal monitoring, but has not yet been accepted by the Division, It does remain a possibility, however.