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.~ III IIIIIIIIIIIIIIII STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources ~s;p°'c4o~ Nei 1313 Sherman St., Room 215 Denver, CO 80207 ~. Phone: 13031 866-3567 • revc FAX: (30318)28106 Roy Ramer Governor October 14, 1993 Michael B. Long Division Dneclor Mr. Murari P. Shrestha Assistant Manager of Engineering Western Fuels - Utah - Inc. 405 Urban Street, Suite No. 305 Lakewood, CO 80228 RE: Review of 1991 and 1992 Annual Hydrology Reports (C-81-018) Dear Mr. Shrestha: The Division has reviewed the 1991 and 1992 Hydrology Reports for the Deserado Mine and has made the following observations. The current PHC contains no predictions or determination of TDS levels. Determinations must be made based on the past observations and present trends. These determinations need to be incorporated into the PHC and AHR (2.05.6(b)(iii)). 2. The mine is experiencing elevated TDS levels in mine inflow and discharging elevated TDS waters into the White River. This issue needs to be outlined and explained in the PHC with a followup in the AHR until the problem is corrected. 3. Future AHR's need to include data from the NPDES discharge monitoring points. As with the surface water and ground water data, the NPDES data need to be interpreted with respect to the PHC and impacts on the hydrologic regime. To address issues 1 and 2, the Division recommends the following actions: A. REVISION OF THE PERMIT'S PROBABLE HYDROLOGICAL CONSEQUENCES SECTION TO INCLUDE TDS DETERMINATIONS. The permit, PHC or AHR's do not include determinations or predictions for Total Dissolved Solids(TDS) or any other water quality parameters. In accordance with Rule 2.05.6(b)(iii), these determinations must be made and included as part of the PHC. The Division recommends the following procedure: That the PHC be revised as part of the upcoming permit renewal to include TDS levels that have been (past) and are currently being observed in both the ground an d. surf ace waters.