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gichard D. Lamm Governor DEPARTMENT OF NATURAL RESOURCES David H. Getches, Executive Director MINED LAND RECLAMATION DI\ DAVID C. SHELTON, Director March 21, 1986 Mr. Richard A. Mills Colorado Yampa Coal Company 29588 Routt County Road No. 27 Oak Creek, Colorado 80467 Re: Evaluation of Eckman Park 1985 Annual Hydrologic Report, Permit No. C-81-071 Dear Mr. Mi11s: The Colorado Mined Land Reclamation Division (CMLRD) would like to acknowledge receipt of the 1985 Annual Hydrologic Report (AHR) for Energy 1, 2 and Eckman Park 14ines. A five-phase analysis of the AHR was performed on the report. An assessment of compliance with the monitoring plan, an evaluation of data interpretation, an analysis of laboratory quality control, an appraisal of the contents of the AHR, and an examination of exceedences from Twentymile Park Receiving Stream Standards and the associated potential for material damage. An evaluation of the first four phases follows; a letter will follow by the end of the month discussing the last phase. Monitoring Plan Compliance The Division was concerned to discover that a considerable quantity of data was not reported. Surface discharge point data does not correspond to the list of sites nor the list of parameters found in the AHP.. One surface water monitoring site (111) was not sampled throughout the year and a number of parameters were not missing most or all accompanies that NOV. sampled on a regular basis. All of the bedrock wells were of the field monitoring data during the winter and summer quarters, and zinc was never analyzed on the required biannual basis. Field parameters and zinc were also omitted for many monitoring periods for the alluvial wells. Two of the three spoils wells had incomplete monitoring results. CLMRD is committed to the maintenance of the monitoring plan approved in the permit, and subsequently issued Notice of Violation (NOV) No. C-86-023 on Harch 20, 1986, A list of missing monitoring occurrences Surface discharge point data is reported to both CMLRD and the Colorado Department of Health on a quarterly basis and is not included in the AHR. This is a legitimate policy, but the Division would prefer that the data be included in the AHR. However, Sites 47, 49 and 51 were not monitored throughout the year. Sites 41, 57 and 91 were discontinued in 1983 and should be removed from the listing of monitoring in the AHR. Site 84 (Discharge Point 005) is not listed in the AHR, but is a full suite NPDES site. The summary tabulating of monitoring parameters for this site should be adjusted accordingly. The AHR and the NPDES permit differ on the parameters being monitored and the frequency of monitoring as follows: 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 • iiiiiuiiiiiiiiiiu 999