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<br />~II ~I~~I~III~~~~ ~II <br />sss <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1 313 Sherman 51., Room 215 <br /> <br />Denver, Colorado 80203 I~~ <br />Phone: 13031 866-3567 ~ <br />FAX: 13031 832-8106 <br /> DEPARTMENT OF <br /> NATURAL <br /> RESOURCES <br /> <br />DATE: May 23, 1996 Roy Romer <br />Governor <br /> tames S Lochhead <br /> <br />TO: Dan Mathews Eeemuve D~reaor <br /> Michael B. Long <br /> Division Duenor <br />FROM: Susan Bnrgmaier <br />RE: McClane Canyon Mine (C-80-.004) <br />Munger Canyon Mine (C-81-020) <br />1995 Annual Hydrology Report <br />I have completed a review of the surface water portion of the Annual Hydrology Report (AHR) <br />for the McClane Canyon and Munger Canyon Mines. I did not see a memo from you as to <br />whether you reviewed compliance with monitoring frequency for the sites. I did not review <br />whether Grand Valley Coal Company (GVCC) conducted all of the required monitoring at both <br />operations. I did, however, review the results of the monitoring reported, comparing that <br />information with baseline monitoring, monitoring since the operations were permitted, and the <br />predictions of probable hydrologic consequences (PHC). Based on that review, I have the <br />following comments. Since I just looked at the same information for the McClane Canyon <br />renewal, some of these comments are carried over from my memos to you on the renewal. <br />1. The PHC section of the McClane Canyon permit predicts impacts to surface water will <br />be minimal. The Munger Canyon permit predicts impacts to surface water will range <br />from insignificant to nonexistent. Neither permit quantifies predicted impacts. As such, <br />monitoring to date is consistent with predictions, in that there seem to be no noticeable <br />mine related impacts to East Salt Creek, to which both operations drain. <br />2. There have been increases in suspended solids, both upstream and downstream of the <br />mines, in response to large precipitation events. The precipitation data provided in the <br />Annual Hydrology Reports correlates large events with increases in suspended solids. <br />3. Dissolved solids have remained relatively .constant over the period of record. Increases <br />downstream are parallelled by upstream degradation in McClane Creek, Munger Creek, <br />and East Salt Creek. <br />4. As I mentioned in my May 16, 1996 memo to you regarding the McClane Canyon permit <br />renewal, GVCC does not monitor flow at SW-8. In accordance with Rule <br />2.05.6(3)(iv)(C), and to make the surface water quality information more meaningful, flow <br />must be measured. Without flow measurement, if there were inconsistencies in quality <br />