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Mr. Basil Bear <br />Beaz Coal Company <br />Page 2 <br />May 22, 1998 <br />througha technical revision to the permit. Please provide a proposed plan for replacement <br />of this well or provide a technical revision which substantiates removing this well from the <br />program. <br />2. No data were presented for the Lower French Drain surface water monitoring point. The <br />Division understands that recent reclamation has occurred in this area of the mine site, <br />however; no explanation was provided in the AHR as to why samples were not <br />collected reported. Please provide an explanation as to why these data were not reported. <br />Removal of the Lower French Drain from the monitoring program will require a technical <br />revision to the permit. <br />3. The locations of the French Drains aze not shown on Figure 11 as stated on page 4 of the <br />AHR. If appropriate, please provide the locations of the French Drains on a revised Figure <br />11. <br />4. The permit requires that water samples be collected from the North Fork of the Gunnison <br />River during June and December. Please provide a brief explanation why samples were <br />collected in May rather than June. <br />5. Sample data for iron and manganese for the North Fork of the Gunnison River are reported <br />in total recoverable and total concentrations for the May and December sample dates, <br />respectively. Data for 1996 (when biannual monitoring of the river began) is reported in <br />total concentrations. A potential concern with the way these data aze presented is that stream <br />water quality standazds aze in either total recoverable or dissolved concentrations. The <br />metals data presented in total concentrationsare not directly comparable to total recoverable <br />concentrations. For surface water, Rule 2.04.7 (2) requires that total and dissolved iron and <br />total manganese be analyzed. The Division recommends being consistentbetweentntal and <br />total recoverable concentrations. For future analyses, please report the iron and manganese <br />in total concentrations so that they can be compared to established baseline data, and add <br />dissolved iron to the sampling program for the North Fork of the Gunnison River so that <br />iron levels in the stream segment can be compared to the water quality stream standard. <br />6. The Division notes that substantial increases in flow were reported for all springs in the <br />monitoring program for 1997 versus flow reported for springs in 1996. Does Bear have any <br />indication where the additional spring flow is coming from? If so, please provide any <br />available information on the source of the increased flow. <br />