2008-08-28_REVISION - C1980004 (2)

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STATE OF COLORADO Bill Ritter, Jr., Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORTUNITY EMPLOYER Thomas E. Remington, Director 6060 Broadway Denver, Colorado 80216 Telephone: (303) 297-1192 wildlife. state. co. us Northwest Region Service Center 711 Independent Avenue Grand Junction, CO 81505 Telephone: (970) 255-6100 Colorado Division of Reclamation, Mining & Safety Attn.: Mr. Michael P. Boulay 1313 Sherman Street, Room 215 Denver, Colorado -80203 - Dear Mr. Boulay, For Wildlife- For People OECEIVE p AUG 2 a 2008 AlWai n%Wo08 Mining ana la et feat ion, The Colorado Division of Wildlife has reviewed the information you forwarded detailing the operator's response to our comments dated January 25, 2008 concerning the McClave Canyon coal mine TR-16 application. As you may recall, most of our concerns focused on potential water quality impacts to East Salt Creek due to the discharge of untreated mine water and gob pile leachate into the East Salt Creek drainage, where it will be.available,to wildlife. We also recommended lining of the sediment pond, fencing of the pond to deter wildlife use,' and including provisions for escapement of wildlife that enter the pond. In their response, CAM Mining, LLC agreed to realign the sediment pond fence and provide a 5:1 ramp for escapement of wildlife. We view those changes as positive for wildlife. CAM's response also stated that, while it believes "it is in the interest of everyone that the water discharged into East Salt Creek be of the highest standard possible", it does not believe the pond needed to' be lined. CAM noted that the previous McClane mine sediment pond, which was much smaller in size and probably handled a much smaller volume of water (and none of the leachate associated with the Munger Canyon gob), was not required to be lined. They add that the nearby Munger Canyon mine also had an unlined sediment pond that discharged into the usually dry Munger Creek drainage. CAM cites a concept it describes as "past accepted precedence" to support its view that the McClane pond should not be lined. We note that both the McClane and Munger Canyon mines were permitted many decades ago, when environmental standards were much different than they are today. We believe that adherence to current environmental standards and best management practices will better protect wildlife and the water they are so dependent upon. CAM also states that the mine water and gob pile leachate to be discharged as surface water into East Salt Creek will notdegrade, and will instead improve, the water quality. They include hydrologic references that contrast the conductivity/salinity of mine water discharge with that of a nearby surface well (S W-1) and ground well (GW71) during the irrigation season. By adding better poor quality water to worse poor quality water, CAM postitlates that they will' actually_be'improvirig overall water quality. As'stated in our January comments, we believe the addition of mine.water-and'gob leachate with DEPARTMENT OF NATURAL RESOURCES, Hams D. Sherman, Executive Director WILDLIFE COMMISSION, Robert Bray, Chair • Brad Coors, Vice Chair • Tim Glenn, Secretary Members, Dennis Buechler • Jeffrey Crawford • Dorothea Farris • Roy McAnally • Richard Ray • Robert Streeter Ex Officio Members, Hams Sherman and John Stulp