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r <br />CDOW is aware of and has noted the existence of several streams containing water that have not been <br />surveyed for biological data and are in relative proximity to the project area. Further, CDOW recently <br />documented the presence of fish species and toads within East Salt Creek; this new information was <br />recently submitted in a Colorado Water Quality Control Commission (WQCC) hearing on October 26, <br />2010, (see attached CDOW hearing rebuttal). The information provided to the WQCC, based on the <br />recent CDOW findings, states the following: "given the limited mobility of larval fish, it is likely that East <br />Salt Creek supports spawning and rearing for sensitive life stages of native suckers. The CDOW also <br />wishes to emphasize that, like the bluehead sucker collected in East Salt Creek by GEI (CAM Exhibit 4, <br />page 27), flannelmouth sucker are a declining native species (Rees et al. 2005). Along with five other <br />states and federal agencies, the CDOW is a signatory to the Range-Wide Agreement and Conservation <br />Strategy aimed at the cooperative conservation of roundtail chub, bluehead sucker, and flannelmouth <br />sucker (Karpowitz 2006)." <br />It is the understanding of the CDOW that one outcome of this hearing included the WQCC's re- <br />.segmentation of the fast Salt Creek drainage. This resegmentation will likely result in additional <br />protection of the documented aquatic resources of East Salt Creek through the water quality standards <br />process. Thus, the CDOW continues to recommend that BMPs (lining or piping of ditches, lined <br />sedimentation ponds, and vigorous vegetation and reclamation actions) be employed by CAM to <br />maintain or improve the existing water quality of East Salt Creek. Aquatic resources of the East Salt <br />Creek drainage stand to benefit from such actions applied and monitored by CAM. <br />Section 1.1.1 indicates that a section of McClane Wash will be placed in a large culvert and the <br />drainage filled to make room for operations. The CDOW recommends that no ephemeral drainage be <br />filled. The Army Corps of Engineers will need to be consulted on the activity. <br />Section 4.5.1 of the Waste Rock Disposal Site and Coal Storage Area report states that the project will <br />not affect flows in East Salt Creek, and that it is unlikely that seepage from an unlined pond would add <br />significant amounts of selenium from soils to the creek. The report lacked documentation for those <br />conclusions, and failed to address the addition of mine water and gob pile leachate to the wastewater <br />stream. On the surface, it appears that the referenced study by Leib concerning selenium leaching <br />would lead to a conclusion that since the waste rock site has not been previously irrigated, selenium <br />leaching would in fact occur. It would also appear that discharges from the wastewater pit into East <br />Salt Creek would inherently impact the hydrological cycle of the creek. We are unable to comment on <br />potential wildlife impacts related to water discharged into East Salt Creek from the wastewater pit <br />without knowledge of the specific components and anticipated amounts of both mine water and gob <br />pile leachate in the wastewater stream. <br />The CDOW recommends that ditches for routing surface water runoff from the waste rock pile should <br />be lined or piped, as many of the Grand Valley irrigation canals are. Lining/piping will reduce seepage <br />of wastewater into groundwater, as well as reduce the potential for selenium to leach into <br />wastewater. Leaching of selenium into unlined ditches, sedimentation ponds, and coal waste rock <br />piles will increase selenium concentrations within the sedimentation ponds. Ditches designed to divert <br />undisturbed area runoff away from sedimentation ponds should not be diverted to any existing <br />drainages. All runoff should be directed toward sedimentation ponds, and manages with effective <br />BMPs that are routinely monitored and evaluated for efficiency. <br />The CDOW continues to recommend that these sedimentation ponds, coal waste rock piles, and <br />ditches be lined/piped, so that runoff and wastewater will not be allowed to infiltrate into the ground <br />and cause increased groundwater contamination.