2011-12-01_APPLICATION CORRESPONDENCE - C2010089 (2)

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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. Also, at the time of bond release, Rule 3.03.2(2) requires the Division to make an evaluation that surface or subsurface water pollution is not occurring. Therefore, all relevant chemical parameters need to be included in the water monitoring program. Please include these chemical constituents in Table 3 and in future surface water and ground water sampling or justify the omission of these heavy metals in the surface water and ground water parameter list. Also, please ensure that the species for each chemical parameter is included in Table 3 and is the species that is monitored. The ground water parameters include both total and dissolved species for some constituents. For surface water parameters, each species should be consistent with the species listed for the San Miguel River stream segment 12 in Regulation No. 35 of the CDPHE Water Quality Control Commission's "Classifications and Numeric Standards ". The internet address is: http: / /www.cdphe.state.co.us /op /wgcc /Standards /RegsCurrent /35 2011(06)tables.pdf Response — These parameters have been added to surface and ground water monitoring programs. Appendix 2.05.6(3) -3 Hydrologic Monitoring Plan has been revised. b) There are several spoil springs and surface water monitoring sites that are associated with previous mining that, according to the permit text, will be used or reactivated to monitor the effects from the New Horizon North Mine. Please add these additional water monitoring sites to the tables in Appendix 2.05.6(3) -3 if they are part of the New Horizon North Mine water monitoring program. Also, the baseline and operational water monitoring results from these sites should be submitted as part of the New Horizon North Mine. Finally, it would avoid confusion if the permit text explains that these sites had been associated with previous mining but are now being used to also monitor the New Horizon North Mine. Response —The sites have been added to Appendix 2.05.6(3) -3 and the baseline data has been included. A discussion of the sites (particularly SW -N1 and SW -N3) has been added to section 2.04.7. Joe Dudash Email of November 17, 2011 to Ryan Lunde I said that I would get back with you when I knew more concerning your proposal. Marcia e- mailed a map to me that shows the location of SW -N1. The use of SW -N1 and SW -N3 on Tuttle Draw looks reasonable. However, the Division needs to know what surface water data is available for SW -N1 and SW -N3 before we can agree with Western Fuel's proposal to use the current NH operational data as NHN baseline for SW -N1 and SW -N3. Appendix 2.04.7 -2 has data from 1985 through 1987 for those two sites. It appears that the post -law mine disturbances at NH occurred before that time period so this data would not be true post -law baseline. Does Western Fuels have data from SW -N1 and SW -N3 that are post -law but pre -mine disturbance? Page 33