2011-09-16_APPLICATION CORRESPONDENCE - C2010089

• Permit No: C2010089
• IBM Index Class Name: APPLICATION CORRESPONDENCE
• Doc Date: 9/16/2011
• Doc Name: Additional Comment for Adequacy Review
• From: Joe Dudash
• To: Marcia Talvitie
• Email Name: MLT
• Email Name: JJD
• Email Name: SB1
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
Date: September 16, 2011
To: Marcia Talvite
From: Joe Dudash
STATE OF COLORADO
Mike King
Executive Director
Loretta E. Pineda
Director
RE: New Horizon North, Permit No. C- 2010 -088, Western Fuels Colorado LLC
New Permit Application, Additional Comment for Adequacy Review
The following is one additional comment that I have for the adequacy review of Western Fuels'
responses, dated May 26, 2011, to the Division's adequacy review letters dated December 23, 2010,
January 5, 2010 and February 18, 2011 for the New Horizon North Mine. I believe Sandy will be
sending this comment to Western Fuels.
John W. Hickenlooper
Governor
25a. The CDPHE receiving stream standards for Segment 12 of the San Miguel River include
standards for certain heavy metals that do not appear in the surface water baseline data of
Appendix 2.04.7(2) or in the operational monitoring program presented in Table 3 of Appendix
2.05.6(3) -3. These heavy metals include arsenic, boron, cadmium, chromium III, chromium IV,
copper, cyanide, mercury, nickel, silver, uranium and zinc.
Rule 2.05.6(3)(b)(iv)requires that the operator have a hydrologic monitoring plan in place to
determine the impact on the hydrologic balance. Under Rule 2.05.6(3)(b)(iv)(D), the Division
can require the monitoring of additional water quality parameters in this hydrologic
monitoring plan if warranted by site - specific conditions and for good cause shown.
The chemical analyses for overburden, interburden and underburden presented in Appendix
Table 2.04.6 -2 show that some of these metals are in the rocks, although chromium, cyanide,
nickel and silver were not sampled. The Division believes that, because these heavy metals
have receiving stream standards and because these heavy metals are present in the rocks at the
New Horizon North Mine, the surface water monitoring program should include these chemical
constituents.
Likewise, the Division's Guidelines for the Collection of Baseline Water Quality include
arsenic, cadmium, manganese, mercury, and zinc (dissolved species) and these were not
included in the Water Quality Parameter List for groundwater. Further these constituents are
included in the Basic Standards for Groundwater (Tables 1 and 3). The Division believes that
these constituents should also be included in the approved water monitoring program for
groundwater.
Office of Office of
Mined Land Reclamation
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
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