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STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources 1313 Sherman 5t., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 March 15, 2004 Tonya Hammond J.E. Stover & Associates 2768 Compass Drive, Suite 101 Grand Junction, CO 81506 RE: Snowcap Coal Company, Inc. Roadside Mine Permit No. C-1987-041 2003 Annual Hydrology Report Dear Ms. Hammond: COLORADO DIVISION O F MINERALS GEOLOGY REC LAM ATION•M INING SAFETY•SCIENCE Bill Owens Governor Russell George Executive Director Ronald W. Cottony Division Director Natural Resource Trustee We have completed our initial review of the 2003 Annual Hydrologic Report. The report covers the water year October 1, 2002 through September 30, 2003. In general, we have found the report to be complete and well organized, with format and content consistent with previous reports, and largely in compliance with permit and regulatory requirements. Data and narrative included in the report demonstrate that hydrologic effects of the operation are in conformance with probable hydrologic consequences (PHC) projections of the approved permit. We have identified only two adequacy concerns based on the review, presented here below. Narrative regarding Minevvater Discharge Point 015, on page 3, is outdated and will need to be amended. Specifically, the third paragraph indicates that "the site is permitted to allow pumping water from the south end of the Roadside South Portal out the 2 West Portals". In fact, this site was never used for discharge, the portal has been sealed and reclaimed, and the discharge site is now officially "inactive". 2. The permit was amended last year to specify reporting of "dissolved" constituents, rather than "total", for the annual full suite monitoring. Dissolved constituents were reported, with a couple exceptions. In Table SU-2, NPDES Point 016 (Minewater Discharge), Chloride, Fluoride, and Phosphorus are reported as "Total", rather than "Dissolved". Chloride is also reported as "Total" on Tables GE-10 and GE-11, for Rollins Wells 2 and 3. Also, the approved surface water monitoring list (applicable to minewater discharge) specifies that phosphorus be reported as phosphate, but as noted, in Table SU-2, it is reported as "Phosphorus, Total". Please submit appropriately amended page 3 narrative for the 2003 AHR, pursuant to Item 1, and please ensure that future analyses for the parameters identified in Item 2 are reported as "dissolved", rather than total. Please contact a if you have any questions. Sincerely, ~~ Daniel T. Mathews Environmental Protection Specialist Office of Office of ~ Colorado