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<br />Richartl D. Lamm <br />Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />Davitl H. Getches. Enecutive Director <br />MINED LAND RECLAMATION DI\ <br />DAVID C. SHELTON, Director <br />April 17, 1986 <br />Mr. Richard Mills <br />Colorado Yampa Coal Company <br />29588 Routt County Road 27 <br />Oak Creek, Colorado 80467 <br />Re: Water Quality Issues at Mines Nos. 1, 2, 3 and Eckman Park - <br />File No. C-81-071 and C-036-81 <br />Dear Mr. Mills: <br />Recently the Division completed a review of your 1985 Annual Hydrologic <br />Reports. Our comments on the reports were forwarded to you by letter on, As <br />we indicated in that letter the Division has identified several additional <br />water quality items that need to be addressed, The items pertain to water <br />quality standards applicable to Foidel Creek, Fish Creek, Middle Creek, and <br />Trout Creek. This letter will provide you with the specifics of our concerns <br />and discuss how these issues might be resolved. <br />Our review of your 1985 hydrologic monitoring data reveals that segments of <br />Foidel and Middle Creek contained high levels of Total Dissolved Solids <br />(TDS). The TDS is attributed primarily to elevated sulfate, calcium, and <br />magnesium levels. The Division has compared the TDS levels to published crop <br />salt tolerance levels for irrigated crops grown in the region to ascertain the <br />seriousness of the situation. <br />As you know, the Water Quality Control Division has not adopted any receiving <br />stream standards for TDS. However, the Mined Land Reclamation Division (MLRD) <br />Alluvial Valley Floor (AVF) regulations do specify crop salt tolerance <br />standards for assessing material damage in Rule 2.06.8(5)(c)(i). This Rule <br />references threshold electrical conductivity (EC) levels for various crops <br />contained in "Crop Salt Tolerance - Current Assessment" by E. V. Maas and <br />G. J. Hoffman, Journal of the Irrigation and Drainage Division, A.S.C.E., <br />1977. This reference was also in the original Federal Permanent Program <br />Regulations. <br />The Division has made affirmative findings for the existance of alluvial <br />valley floors (AVF) along portions of Foidel Creek, lower Fish Creek, lower <br />Middle Creek, and lower trout Creek. <br />Although AVF determinations and vegetation inventories have not been made for <br />all areas downstream from your mines, the Division examined salt tolerance <br />levels for various cropps which are typically grown in the Yampa River Basin, <br />such as alfalfa, timothy, smooth brome and orchard grass. For the purposes of <br />the assessment we utilized a soil extract EC suspect level of 1500 umhos/cm. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />