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7. Rule 3.03.2(2) DifFculty to Complete Reclamation <br />The Division will determine the degree of difficulty to complete any remaining reclamation. <br />The Division has determined that there is no remaining reclamation to be accomplished. <br />8. Rule 3.03.2(2) Pollution of Surface Water <br />The Division will determine the degree of pollution of surface water. <br />The Division has considered, among other things, the results of inspections and monitoring conducted <br />pursuant to Rules 4.05 and 5.02, to determine whether pollution of surface water is occurring. In <br />addition, the Division reviewed surface water quantity. The permittee complied with the requirements <br />of Rules 4.05.13(2). Monitoring programs, approved by the Division, were developed and <br />administered (Permit, Chapter G, and Annual Hydrologic Reports). The permittee presents <br />information in the application that supports a conclusion that there has been no long-term change to <br />water quality in the Curtis Creek watershed. No negative effects to surface waters was demonstrated <br />by 1985, and surface water quality monitoring was terminated by the Division except for National <br />Pollution Discharge Elimination System (NPDES) monitoring programs with regard to sedimentation <br />pond discharges. The table in Document 20 presents surface water quality information extracted from <br />the Permit, the 1985 Annual Hydrologic Report, and the Application. <br />The Classifications and Numeric Standards for Curtis Creek (from the Classifications and Numeric <br />Standards for Lower Colorado River Basin 3.7.0, Colorado Department of Health Water Quality <br />Control Commission, effective August 39, 1995) are dissolved oxygen = 6.0, pH = 6.5 - 9.0. There <br />are no inorganic or metal standards. From [he information presented in Document 20 and Permit <br />reports on file, the Division finds, with the exception of calcium, all 1997 water quality parameters <br />within or below baseline ranges for the sample station below mining activity (HRS-2), and this calcium <br />parameter represents no adverse impact to the beneficial use of the water. From the information <br />presented, the primary source of elevated parameters in samples taken downstream of mining activity <br />appears to be the discharge from the developed well near the Rienau rY 2 mine portals. Baseline <br />information indicates, however, that this seep had similar impacts to Curtis Creek prior to Enron <br />mining activity. A copy of the water quality analysis (sample of 9/9/97) of the final water sample of <br />the well on the Rienau # 2 mine site was provided (Division letter, 29 October 1997, copy at <br />Document 3) to the White River Resource Area, Bureau of Land Management (per their request, letter, <br />September 18, 1997, at Document 17). <br />From the information provided, the Division concludes that compliance with Rule 3.03.2(2) has been <br />demonstrated. No pollution abatement (no estimated cost) is warranted, and the probability of <br />degradation of existing water quality is low. <br />24 20 January 1998 <br />