2008-02-01_REVISION - C1980004

• Permit No: C1980004
• IBM Index Class Name: REVISION
• Doc Date: 2/1/2008
• Doc Name: Review Letter
• From: Division of Wildlife
• To: DRMS
• Type & Sequence: TR16
• Media Type: D
• Archive: No

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STATE OF COLORADO
Bill Ritter, Jr., Governor
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WILDLIFE RF-CEWE®
AN EQUAL OPPORTUNITY EMPLOYER
Thomas E. Remington, Director FEB 01 ZOOS
6060 Broadway
Denver, Colorado 80216 Division 0reciamation,
Telephone: [phone] Mining and Safety
wildlife. state. co. us
January 25, 2008
Colorado Division of Reclamation Mining & Safety
Attn: Dar. Mathews
1313 Sherman Street, Room 215
Denver, CO 80203
Dear Mr. Mathews:
4
rod, OF
For Wildlife-
For People
The Colorado Division of Wildlife has reviewed Technical Revision 16 Application for the McClane
Canyon coal mine in Garfield County. The application was prompted by the closure and reclamation of
the nearby Munger Canyon mine site, and the enactment of new rules regarding waste rock storage
inside active mines. The coal mine operator seeks to create a waste rock storage site with a final
capacity of 38,000 cubic yards of mine waste. The disturbed area, including gob, soil stockpiles, and
sedimentation pond is anticipated to impact 4.75 acres. The disturbance is sited at the mouth of
McClane Canyon, and immediately east of East Salt Creek.
During our review it was noted that the applicant seeks to discharge from the sedimentation pond
directly into McClane Canyon, a few hundred yards from its junction with East Salt Creek. East Salt
Creek is a major tributary connecting the Bookcliffs to the Colorado River. Its flow is intermittent in
nature, often dipping below ground and reappearing occasionally along the stream course during the
dry summer months. East Salt Creek is critically important to many species of wildlife year round.
Our main concerns with this application center upon the potential impacts to wildlife due to impairment
of water quality. The flow rates indicated in the application could result in the mine discharge
constituting most of the flow in East Salt Creek at times. We are particularly concerned about the runoff
of gob pile leachate and the effects of its discharge into East Salt Creek. The applicant provided data
indicating that the combined discharge of mine water and leachate was anticipated to be higher in
quality than some of the water sampled from adjacent surface and ground wells. The applicant stated
that because of this, discharge of the waste water would increase water quality. We note that the
discharge of contaminates is additive to the water system.
The application would appear to require a National Pollutant Discharge Elimination System (NPDES)
permit. We anticipate that the Colorado Water Quality Control Division will evaluate the quality of the
anticipated discharge, and the need for treatment to lower contaminate levels. We feel compelled to
point out that game wildlife, including chukar, morning dove, cottontail rabbit, mule deer and elk are
dependent on the water in East Salt Creek. Those animals are also heavily hunted, so there is a direct
link between habitat quality and the human food chain. It is in the interest of the hunting public that
the water discharged is of the highest practical quality.
DEPARTMENT OF NATURAL RESOURCES, Harris D. Sherman, Executive Director
WILDLIFE COMMISSION, Tom Burke, Chair • Claire O'Neal, Vice Chair • Robert Bray, Secretary
Members, Dennis Buechler* Brad Coors • Jeffrey Crawford • Tim Glenn • Roy McAnally • Richard Ray
Ex Officio Members, Harris Sherman and John Stulp