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r, <br /> III IIIIIIIIIIIIIIII <br />999 <br /> STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl of Natural Resources <br />1313 Sherman St., Room 215 u <br /> <br />Denver, Colorado 80203 Il <br />~~ <br /> <br />Phone: f303) 866-3567 I <br />FAx: (3031 832-8106 <br /> DEPARTMEIJT OF <br /> S CES <br />September 6, 1996 RE OUR <br /> Roy Ramer <br />Ms. Christine Johnston eavernar <br />Mountain Coal Company Tames 5. Lochhead <br />P. O. Boz 591 Executive Dueaor <br /> <br />Somerset, Colorado 81434 Michael B. Long <br />Division Dueclor <br />Re: Review of 1995 Annual Hydrology Report; West Elk Mine; Permit No. C-80-007 <br />Dear Ms. Johnston: <br />The Division has reviewed the 1995 Annual Hydrology Report (AHR) for the West Elk <br />Mine. This letter presents the Division's comments and recommendations regarding the <br />1995 report. Several deviations from the approved monitoring plan were noted for the <br />frequency of data collection as required by the 1995 Water Year monitoring plan. <br />A summary of the main water quantity and quality issues identified based on the Divisions's <br />review are provided in the following paragraphs. Specific comments are provided below. <br />Cumulative water quantity effects on the North Fork Gunnison River down gradient of the <br />West Elk Mine cannot be adequately assessed without flow measurement data from the <br />North Fork Lower station. The Division recommends that flow measurements at the North <br />Fork Lower station be added to the water quality monitoring program. Another water <br />quantity concern is the accurate documentation of mine inFlow water and its ultimate <br />disposition. If water is being discharged or Bumped in the mine then the discharge must be <br />discharged as a controlled and identifiable Flow and be ultimately treated by an existing <br />treatment facility (see comment No. 9 below). <br />Based on the data presented for WY 1995, there does not appear to be a significant <br />difference in water quality between the North Fork Upper and North Fork Lower stations. <br />It appears that in May 1995 iron (total) exceeded the water quality standard for Stream <br />Segment 2 North Fork of the Gunnison River, at both the North Fork Upper and North <br />Fork Lower stations. One of the problems with the metals data as they are presented is that <br />stream water quality standards are in either total recoverable or dissolved concentrations. <br />The metals data presented for the North Fork Upper and North Fork Lower stations for <br />WY 1995 are in total concentrations, which are not directly comparable to total recoverable <br />concentrations. Thus, the Division has recommended in the past that both total and <br />dissolved analyses be presented for iron and manganese for the North Fork stations. The <br />total concentration can be used to compare with established baseline data and the dissolved <br />