2008-08-28_REVISION - C1980004

• Permit No: C1980004
• IBM Index Class Name: REVISION
• Doc Date: 8/28/2008
• Doc Name: Review & Response
• From: Division of Wildlife
• To: DRMS
• Type & Sequence: TR16
• Media Type: D
• Archive: No

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: [phone]
wildlife. state. co. us
Northwest Region Service Center
711 Independent Avenue
Grand Junction, CO 81505
Telephone: [phone]
Colorado Division of Reclamation, Mining & Safety
Attn.: Mr. Michael P. Boulay
1313 Sherman Street, Room 215
Denver, Colorado 80203
Dear Mr. Boulay,
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For Mldlife-
For People
RECEIVED
AUG 2 a 2008
Mi *14,,e0c0ia
Mining and mation,
Safety
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 McClane 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 not degrade, 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 (SW-1) and ground well (GW-1) during the irrigation season. By adding better poor quality water
to worse poor quality water, CAM postulates that they will actually be "improving 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