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November 2, 2011 C- 1980- 007/West Elk Mine MPB <br />On Wednesday morning, I was directed by Senior Staff to conduct an inspection of the West Elk Mine and to <br />inspect the North Fork of the Gunnison River and retrieve samples for laboratory analysis if deemed necessary. I <br />placed a call to Kathy Welt and left a voice message that I would be conducting the inspection on that day. I <br />arrived in the Paonia area at approximately 12:00 p.m. and began my inspection by viewing the North Fork of the <br />Gunnison River at several vantage points to determine if there was any sign of red material remnant in the river or <br />any other potential environmental damage. I photographed the river at various locations from the bridge at the <br />town of Paonia all the way up to the West Elk Mine property. Several photographs are attached at the end of this <br />inspection report. Photograph No. 1 shows the river from the bridge at Milepost 14 approximately four miles <br />downstream from the mine site. Photograph No. 2 is a panoramic view of the river looking to the southwest from <br />the bridge crossing at the Bear No. 3 Mine less than one mile downstream from West Elk Mine site. There was no <br />evidence of red material at any of the vantage points along the river. There was no fish kill noted and no visual <br />evidence of any kind that would indicate an environmental impact. <br />I arrived at the mine site at approximately 1:00 p.m. and met with Kathy Welt, Robin Schiro, and Ryan <br />SWeetNvood of MCC. We met in a conference room for about an hour to discuss the details of what took place <br />leading to the citizen complaint. MCC personnel informed me that they had conducted a mixing zone test in the <br />river just below the outfall of their lowest discharge pond (site MBSE) or outfall 009. According to the MCC <br />personnel, the purpose of the test was to obtain information regarding dilution that may be used by MCC for the <br />purposes of calculating water quality based effluent limitations (WQBELs). MCC indicated that they conducted <br />the test pursuant to their pending NPDES permit renewal application submitted to CDPHE. MCC further <br />indicated that they are interested in obtaining site specific regulations for certain parameters including SAR and <br />temperature and that they believed the mixing zone test was one option for achieving the desired information that <br />would satisfy CDPHE requirements. During the meeting we placed a conference call to Joe Frank of Hydro Geo <br />Consultants. Hydro Geo Consultants was contracted by MCC to perform the mixing zone test. Joe Frank and <br />MCC personnel described the details of the study that was done. According to MCC personnel the test began on <br />November 1, 2011 at 11:00 am. The location of the test site is shown in Photograph No. 3. Also according to <br />MCC personnel, a total of five gallons of red fluorescent dye (rhodaimine) were injected directly to the river at a <br />rate of 2 ounces per minute to achieve a desired dye concentration of 100 parts per billion. MCC personnel <br />indicated that twenty transect stations were set up across the river downstream to monitor the dye concentration <br />and obtain the data necessary to model the dispersion. The details of the study should be available in the near <br />future in a summary report being prepared by Hydro Geo Consultants. More detailed information regarding the <br />study will be contained in this report. MCC indicated that the timing of the study was critical to complete during <br />low flow conditions and they made the decision that the timing was good to conduct the test at the time they chose <br />just prior to the pending storm that was predicted later in the evening and following day. MCC indicated that the <br />dispersion did not occur as expected and that the dye stayed in one concentrated width of about five feet for some <br />distance before dispersing as planned. MCC stated that they did not expect the river to turn as red as it did. MCC <br />personnel offered their conclusion that the test produced the desired results and that the dye was fully dispersed by <br />the time it reached the Fire Mountain Canal head gate. According to MCC, the test was concluded at 6:00 pm and <br />by 3:45 p.m. there was no visual of dve in the river. <br />DRMS was not present during any of the dye testing process, and is in contact with CDPHE regarding the <br />situation. <br />Number of Partial Inspection this Fiscal Year: 6 <br />Number of Complete Inspections this Fiscal Year: 2 <br />Page 3 of 7 <br />