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Western Fuel's proposal to drop sampling of SW -N6, SW -N7 and NPDES 001, since SW -N213 <br />and SW -N214 are being sampled, seems reasonable. <br />Mike Boulay reminded me that the PHC for NHN contains predictions for Coal Creek Canyon, <br />Tuttle Draw, Meehan Draw and the San Miguel River. Therefore, the Division will need up <br />gradient and down gradient baseline and operational surface water monitoring data for those four <br />stream channels in order to verify the PHC predictions. Mike mentioned this in part in his <br />adequacy review questions numbered 10 and 14 of Section 2.05.6(3) Protection of Hydrologic <br />Balance. The NHN permit application needs to be updated to include those six sampling sites in <br />the monitoring plan and the baseline data from those sites that show seasonal variations. Sorry <br />for any confusion on my part. Does Western Fuels have these data already? <br />Response - The New Horizon Mine Hydrology Report data beginning in 2008 for <br />sites SW -N1 and SW -N3 are sufficient baseline data for Tuttle Draw. Regardless of <br />when pre and post -law disturbances occurred, this data is the most current data for <br />these sites and Western Fuels has been diligently monitoring these sites throughout <br />the operation of the New Horizon Mine. These sites clearly identify in detail seasonal <br />variation as required by 2.04.7- 2(2)(a). The NHM data for these sites most <br />accurately reflects the condition of Tuttle Draw prior to disturbance at NHN. <br />With regards to monitoring Coal Canyon and the San Miguel River, regulation <br />2.04.7- 2(2)(a) states: <br />Surface water information shall be provided, including the name of the watershed which will <br />receive water discharges from the permit area, the location of all surface water bodies such as <br />streams, lakes, ponds and springs, the location of any water discharge into any surface body of <br />water, and descriptions of surface drainage systems sufficient to identify, in detail, the seasonal <br />variations in water quantity and quality within the proposed permit and adjacent areas. The <br />application shall also contain information pertaining to ownership and use of surface water <br />bodies. <br />Western Fuels has established surface water monitoring sites that account for all of <br />the surface water entering and leaving the permit boundary. Any surface water from <br />the permit area that goes into Coal Canyon is monitored on the sites at Glasier and <br />Meehan Draws which satisfies the regulation. All surface water ultimately <br />discharges into the San Miguel River. The surface water monitoring program at <br />New Horizon North sufficiently identifies the seasonal variations in water quantity <br />and quality within the proposed permit and adjacent areas. While permit text <br />discusses the probable effects to Coal Canyon and the San Miguel River, regulation <br />2.04.7- 2(2)(a) does not require any further monitoring. New Horizon Mine similarly <br />has discharge that ultimately finds its way into the San Miguel, but there is no <br />requirement for any river monitoring in the New Horizon Mine permit. <br />I believe WFC has responded to DRMS' comments to its satisfaction. WFC requests DRMS to <br />expedite the review of the response and issue a decision to approve the permit application as <br />soon as possible. <br />Page 34 <br />