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Christine Johnston Mountain Coal Company Page 6 November 12, 1997 19. The Division submitted a letter to MCC on December 9, 1996 requesting a minor revision to the permit document to improve the hydrologic monitoring program, which included seven items to be addressed by MCC. The recommendations were presented to MCC, and a revision was requested to ensure that the West Elk Mine hydrologic monitoring plan is incompliance with all applicable requirements. MCC responded with MR-208. The Division found this minor revision to be incomplete. Please refer to the Division's incompleteness letter for MR-208 dated February 27, 1997. As discussed below, several items concerning the AHR and/or hydrologic monitoring still need to be addressed by MCC (for further discussion refer to Division letter to MCC dated February 27, 1997). • MCC was requested to provide mine inflow sample results in AHRs. The permit document should also reflect sampling and reporting procedures for mine inflow water. Analytical results for mine inflow sampling were not included in the 1996 AHR. • MCC was requested to provide more detailed monitoring and reporting of mine inflows. MCC has responded by providing a more detailed explanation of groundwater inflows in the 1996 AHR and by providing greater detail as to the location and duration of inflows. The Division also requested that information on mine water routing and Bumping of inflow water be provided. The 1996 AHR contained inadequate information on routing and Bumping of mine inflow water. The report should include locations and actual storage volumes for significant sump locations. • The Division has requested that laboratory analytical data sheets and associated chain-of-custody forms be provided beginning with WY 1996 AHR. Some laboratory data sheets were provided; however, they were not incorporated as an appendix to the report as requested. As they will be required as a routine submittal for all future AHRs, they should be incorporated as an appendix to the report. Chain-of -custody documentation was not provided. • MCC was requested to provide anion and cation balances to the analytical program for surface water samples to ensure data quality. This was documented in the Division's inspection report dated October 23, 1996. Because this request was made subsequent to the 1996 water year, this information will not be required for the 1996 AHR. Please be sure to include this as part of the analytical monitoring program and update the Table 5 Water Quality Monitoring Program to reflect this additional analyses.