REP26554

• Permit No: C1980006
• IBM Index Class Name: Report
• Doc Date: 4/12/1995
• Doc Name: MEMO MARR STRIP MINE C-80-006 1994 ANNYAL HYDROLOGY REPORT
• From: DMG
• To: MARR STRIP MINE C-80-006 1994 ANNUAL HYDROLOGY REPORT
• Permit Index Doc Type: HYDROLOGY REPORT
• Media Type: D
• Archive: No

STATE OF COLORADO

DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman 51., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DATE: April 12, 1995
TO: Wally Erickson
FROM: Susan Burgmaier
RE: Marr Strip Mine (C-80-006)
1994 Annual Hydrology Report
~I~~
DEPARTMENT OF
NATURAL
RESOURCES
Roy Ramer
Governor
lames 5. Lochhead
Executive Director
Michael B. Long
Division DlreL'lp(
I have reviewed the above mentioned annual hydrology report, and have the following
comments:
Total Dissolved Solids (TDS) has risen significantly at Site AO-2. Unfortunately, due to
the minimal requirements of the monitoring Plan, it is not apparent whether this rise can
be attributed to the mine or to natural conditions. Kerr Coal Company is currently not
required to monitor alluvium upstream of AO-2 (there is a site AO-1 upstream,
however), and so it is impossible to ascertain whether the same rise in TDS is occurring
above the area of mining impact. Please have Kerr explain this increase.
2. At surface water station 300, TDS and sulfate have shown a substantial increase in 1994
comQared to values reported from 1991 through 1993. Again, this station is not
momtored simultaneously with other stations upstream or downstream, so it is difficult
to pinpoint the cause of the increases. Please have Kerr explain this increase.
3. The current monitoring program appears to be inadequate to determine what, if any,
impacts to water quality and/or quantity have been caused by the mine. With the
exception of the loadout, none of the currently monitored sites have a counterpart that
serves as a control. This will make it especially difficult to determine, at the time of
bond release, whether the site has degraded water quality or quantity.
4. Page 21 of the report references Stormwater Exemption Requests made for instances
where TSS and iron values exceeded permit limits. There is not a record of any response
from the Water Quality Control Division. Were the excursions excused?
The annual Well Inspection Report, conducted Apri16, 1994 indicated that well AP-2 was
in need of a casing extension. If we haven't done so already, we should probably check
to see that this was done.
6. The text of the report does not discuss results of water monitoring in relation to
predictions of probable hydrologic consequences made in the approved permit application
package. Since the purpose of monitoring is to verify these predictions, Kerr should
address what their monitoring is telling them. The Division has the ability to require "a
written interpretation of the data and identification of mining related impacts to the
hydrologic balance", per Rule 4.05.13(4)(c)(iii). I believe we should require Kerr to
submit such an interpretation, especially since their monitoring program is so minimal.
Then they might realize that the data they are collecting is essentially worthless in terms