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ti III IIIIIIIIIIIII III <br />Mountain Coal Company <br />West Elk Mine <br />Post Office Box 591 <br />Somerset, Colorado 81434 <br />Telephone 970-929-5015 <br />April ] 0, 1998 <br />Mr. David Berry <br />Colorado Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />RECEIVED <br />APR 15 1998 <br />Division of Minerals & Geology <br />RE: March 19, 1998 Meeting - 1996 Annual Hydrology Report; <br />West Elk Mine; Permit No. C-80-007 - - <br />Dear David: <br />Mountain Coal Company (MCC) appreciated the opportunity to meet with you and <br />Mike Boulay on March 19, 1998, to discuss the 1996 Annual Hydrology Report <br />(AHR). We believe that it was a very productive meeting in that we better <br />understand the adequacy questions on the 1996 AHR and your reasons for issuing <br />the Notice of Violation and understand how we need to move forward to improve <br />MCC's monitoring program. To reiterate our understanding of the discussions <br />during the March 19's meeting, below is a summary of the main ideas. <br />The key words associated with this meeting were "Action Plan". It is evident that <br />MCC needs to communicate problems and issues regarding the monitoring program <br />with the Division in a more timely manner. In addition, MCC should plan to propose <br />an action plan to remedy the problems and issues that arise. This is particularly the <br />case with the groundwater monitoring wells. <br />We discussed the fact that the 1997, 1998, and to some extent the 1999 AI-IRs will be <br />similar to the 1996 AHR. For example, the wells that had problems during the 1996 <br />water year will likely be included in these subsequent reports, as MCC has continued <br />to attempt to collect data from these wells. In addition, the laboratory has probably <br />not been complete in their analysis of all the required parameters. However, these <br />future AHRs will include discussions of MCC's quality assurance, quality control <br />(QA/QC) improvements and our other action plans. MCC has already made QA/QC <br />improvements based on recommendations from the Division and from our <br />consultants. Any action plans discussed in the AHRs, will be immediately followed <br />with a revision application, if appropriate. <br />We also discussed future improvements to MCC's monitoring program. We <br />discussed, in general terms, Alan Mayo's proposal to MCC to evaluate the entire <br />hydrology monitoring program. The proposed evaluation will begin during spring <br />run-off and will continue through low flows in the fall. All groundwater wells, <br />surface water sites, and springs that have been and are currently in our monitoring <br />