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March 1992 Kerr Coal Company Adequacy Responses ~ 1 <br />Rerparcres to Febntmy Iq 1992 CItQ.RD C,arnrnenls <br />1991 Anwd Hydrology Reportt <br />General Comments <br />/. An initial review of the report revealed that a map of the monitoring locations was not included <br />/nvestigation of the monitoring plan within the permit application, page 23-176, references Map 23-2. No <br />reference to a loadout monitoring map is made to either the text or [he report. Please make mention of all <br />maps and monitoring plans in the report so Utat those items can be retrieved to assist in the Division making <br />a thorough review. Many times a stafjhydrologist who is unfamiliar with [he site and Ure permit is assigned <br />to do the review. Any assistance you can provide to make the task quicker and more efficient is a benefit <br />to alt parties. <br />Response: <br />Attached aze copies of [he maps referenced in [he comment letter of February 10, 1992. The maps, <br />Water Monitoring Sites, Map 23-2 and Loadout Hydrology, Map 17a, aze provided to accompany [he <br />1991 Annual Hydrology Report. The 1992 Annual Hydrology Report will contain proper references and <br />maps. <br />2. Site 327 is not shown on the mine area map, probably because it is Jocated a substantial distance east of <br />the permit area. Nonetheless, please add the site to the map with some notation of its approximate location. <br />Response: <br />Please note that the mine area map, Water Monitoring Sites, Map 23-2, has been revised [o locate <br />sampling site 327. <br />Surface Water Ouaotity and Ouality <br />Station 304 is always discharging a trickle, yet no notations were made during sampling. What is [he cause <br />of this discharge and why is it going unnoticed? <br />Response: <br />The discharge tube on Station 304 is constructed with corrugated metal pipe (CMP). Kerr, over the <br />years, has investigated [he source of the continual trickle and has concluded [hat a connection/collar at <br />[he upper end of the discharge pipe is not tight, thereby allowing water to trickle. The trickle is <br />insignificant and does no[ pose a structural problem to the embankment. When [he water level in [he <br />pond reaches or exceeds the design discharge level, the flow is noted and recorded. <br />2. The highest level of dissolved solids and sulfate for the entire mine site is station 306 on Bttsh Draw. Upon <br />inspection, it is noted [hat [his site flows in response to srtowmelt and isolated precipitation events. <br />However, to verify quality vs. flow characteristics, the upstream site 314 was investigated Why does site 306 <br />show relatively extended Jlow while site 314 shows practically none? /nspection of historical data shows that <br />this relationship has existed for some time. Is site 314 in proper position to measure flow? The review of <br />[he 1986 AHR review letter (9-5-871o David Gossett) raises this same issue. The only logical conclusion <br />that can be reached at the present time is shat the surface water in Bush Draw is being negatively impacted <br />due to mining operations. Samples show the TDS at an average level of 2345 mg/!, which is 9x [he <br />domestic suspect level, and over 3r the crop suspect level for North Park No discharge from other sites <br />could be identified to explain either [he flow issue or the quality concern. Please submit your explanation <br />of this phenomenon. <br />Response: <br />Surface water sampling, in general, is difficult at the mine site due to intermittent flow in the area. As <br />mentioned in [he 1991 Annual Hydrology and Annual Reclamation Report, Kerr Coal Company, File <br />c\wh\P7\N<rt\ 1991 TIER <br />LO/11/oZ gam <br />