REP49842

• Permit No: C1981044
• IBM Index Class Name: Report
• Doc Date: 3/19/1997
• Doc Name: EAGLE 5 & 9 ANNUAL HYDROLOGY REPORTS
• From: K GORHAM
• To: B WALKER
• Permit Index Doc Type: HYDROLOGY REPORT
• Media Type: D
• Archive: No

To:
Cc:
Bcc:
From:
Subject:
Date:
Attach:
Certify:
Forwarded by:
WalkerB@COAL@DNRML
HernandD@COAL@DNRML
GorhamK@COAL@DNRML
Eagle 5 and 9 Annual
Wednesday, March 19,
N
Hydrology Reports
1997 0:32:09 UTC
III IIIIIIIIIIIII III
I am not sure that I am answering your question(s) but I will give it a shot
anyway.
From my long experience with Cyprus and Rick Mills, they have always worked
on a water year at the Routt County mines. However, if they want to report
by calendar year at Eagle, that is fine with me, however, I find it confusing
internally for them and my guess is that it will likely result in future
problems since many of the same Cyprus personel deal with all their mines in
Colorado. I would agree with your attempt to define it in the permit.
As far as the submittal date, I am surprised that the permit does not provide
a submittal date deadline for the AHR already. You should check the permit
in detail if you have not already and also check with previous specialists
for the site (Erica, Janet). Bottom line, the submittal date should be in
the permit, clearly stated. If it is not now in the permit, let me know so I
can brow-beat some people at the next staff meeting.
With regard to your comments concerning maximum and minimum values for
baseline and for operational for identification of impacts; That would be
nice, I agree, but the baseline range should be defined in the permit for
each site. In the ideal permit, the baseline data for each site monitored
during the baseline data collection period should be part of the permit
application as an exhibit or appendix to the permit. At the time of AHR
review, the specialist reviews the PHC, the baseline information, receiving
stream standards, the AHR, and any other information to determine if impacts
are developing or occuring. The method of data analysis will vary by
specialist conducting the review but should result in a conclusion of impact
or otherwise. The operator is likely not interested in making it easy for us
to determine if there has been an impact, therefore, it becomes a mini-
investigation each year as to what is going on at the site. Eventually,
electronic submission of data will make it easier and more convenient to
analyze the data but that is a ways out. We can always as:k that the format
their AHR in a certain way but sometimes all we will get is what is required
by the Rules.
Anyway, let me know if you have further questions or comments.