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• five years of data have been accumulated, the annual laboratory analysis will only include TDS, <br />TSS, pH, conductivity and iron (dissolved and total). A seasonal, rather than quarterly or semi- <br />annual water quality monitoring schedule was instituted for a variety of reasons. The primary <br />reason for selecting seasonal sampling is that, in many instances, particulazly streamflow and spring <br />flows, these aze the only periods of measurable flow. Most of the streams aze ephemeral or <br />intermittent at best, and nearly all of the springs aze ephemeral except in the wettest yeazs. The <br />baseline data cleazly indicate that there is no reason to attempt to sample these locations during <br />winter. The adverse conditions encountered in the remote areas of the West Elk Mine lease azea <br />severely hamper sampling procedures and influence the collection of meaningful data. As a result, <br />by restricting sampling to the periods of flow and ensuring sample integrity, Mountain Coal <br />Company will be able to provide meaningful data to the agency while reducing the costs associated <br />with collecting unnecessary data or data that is not meaningful. <br />Mountain Coal Company has selected the water quality pazameters in Table 4, Exhibit 71 for <br />routine measurement because they will adequately characterize the quality of the water. Annual <br />full-suite monitoring (and the reduced pazameter list) will allow Mountain Coal Company to <br />identify possible mining-induced changes in water quality. <br />West Elk Mine, in cooperation with the U.S. Forest Service District Office in Paonia, Colorado, has <br />agreed to informally monitor the U.S. Forest Service surface water resources, as depicted on the <br />U.S. Forest Service Water Resources Map, that aze located directly over panels to be mined, and <br />within the angle-of--draw per the agreement letter in Exhibit 19C. <br />Spring Monitoring <br />In 1977 Mountain Coal Company began a spring water monitoring program that incorporated <br />monthly, quarterly and semi-annual monitoring of flow and/or water quality. Map 37 shows the <br />springs identified on the West Elk Mine lease azea, the monitored springs, the springs sampled for <br />water quality, and the locations of the decreed springs on the West Elk Mine lease area and vicinity. <br />Map 34 shows the location of springs currently in the monitoring program. The most recent <br />Annual Hydrology Report provides a graphic representation of the flow data available for the <br />springs monitored and water quality data. <br />It is estimated that it might be some time before secondary recovery mining will take place south of <br />the Minnesota Creek watershed divide. As a result, there is no need to operate and maintain the <br />entire spring monitoring network until mining advances to a point where a specific spring might be <br />impacted. Rather, monitoring of some of the springs will be stopped until the summer before <br />mining impacts can be expected, at which time monitoring of appropriate springs will be resumed. <br />Monitoring will continue, on a seasonal basis, for the springs in the approved monitoring program <br />as listed on Table 4, Exhibit 71. <br />In the Minnesota Creek drainage basin, monitoring was discontinued for springs J-4, J-7, J-10 and <br />WCC-23 until the summer before mining impacts can be expected, at which time monitoring of <br />these springs will be resumed. Monitoring of spring J-4 was reinitiated in 1996. Monitoring of a <br />group of three springs (G-25, G-28a and G-31) in Gribble Gulch and one spring (G-26a) in Lone <br />• Pine Gulch were discontinued for several years due to access being blocked by landslides. The <br />monitoring of spring G-26a in Lone Pine Gulch, spring G-25 (#15, Jumbo Spring No. 2 Pond) and <br />2.05-73 Revised Dec. 1997 MR208; Revised Jon. 1999 TR88; Rev. Apri(1006 PRI G <br />