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e~ STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Deparlmenl of N, rural Resources 1 313 Sherman 51., Room 21 5 Denver. Colurarlo 80203 Phone: (3031 666-3567 FAY: (3031 632-81 U6 24 September 1997 TO: Dan Mathews ~: ~1F 1 I~~~~'s 3 DEPARTMENT OF NATURAL... RESOURCES' 4 Ruy Roma Governor lames 5. Lochhead FROM: Jim Burner Eienirioe Director Mich. el A. Lung Division D.recror SUBJ: Deserado 199 AHR Dan, I have finally finished reviewing the Deserado AHR and have enclosed the comments below. Therein I have attempted to address all the questions you put to me in your memo of 4- 23-97. I have put the text of this memo on the Mdrive under JRB with the title "Des97.ahr." First of all, I find that there is nothing of particular note in the AHR for 1996. You seemed to do a very thorough job of evaluating the AHR against requirements and picking out contradictions. 1. It appears that the issue of the missing WET test and/or WET test results is at least moot at this point. No further mention will be made. 2. Regazding the need for reporting water quality on mine inflows, let me present the following. Cleazly, the quality of water leaving the mine is an issue relevant to the PHC of the mine. Obviously, bad water entering the influence of the mine cannot be blamed as the cause of bad water leaving the mine if there is no proof that the water entering the mine was of poor quality. So the analysis of inflow water is a safety check for the operator. If the operator is confident that the quality of inflow water won't be ppor enough to call attention to the effluent water, I think we can live with that decision. There seems to be no reason in the Deserado case that influent water would be of particularly bad quality (such as was the case when White River alluvial water was used in their operations and later discharged) so it should probably be no problem. eliminating that requirement. Still, the value of some samples can't be underestimated to save trouble later. 3. When an analyzed value os reported as "analyzed but not detected," the operator should report the detection limit. That way, there is some data to base conclusions on; without it, the reported value is useless. 4. The issue regarding the crest stage guages has been resolved since the AHR was submitted. 5. Regarding the discrepancy in stated sampling frequency for surface water at sites SW 1-1, 11- 1, 23-1, 24-1, 31-I, 6-1 and 33-1 on page A2 of the AHR, I think it's relevant to consider our overall movement toward minimizing sampling requirements. Monthly sampling is overkill, so