_GENERAL DOCUMENTS - C1981017 ‎(249)‎

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Name: Bid Documents ‎(IMP)‎ 1995 Correspondence
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

Crumpacker Coal Basin draft memo re: Task Force"Outline of Procedure For The
Evaluation of the Mid-Continent Proposed Development Plan", Section III,
"Environmental impacts", `B. Streams", "D. Trails and roads".
Two serious problems presently exist with regard to the quality of the water in Coal Creek
and Crystal River: (1) sediment coming down Coal Creek; (2) metals and/or other toxins
coming down Coal Creek. These problems do not exist in the Crystal above Redstone.
They adversely effect the vegetation, insect and aquatic life in these streams. To a
significant extent these problems result from the coal mining which occurred in Coal
Basin, 1955 - 1990 and the terrain changes in the basin which were involved with the
mining. Under the law, see Articles 32 and 33, Title 34, Colorado Revised Statutes and
Article 30, Title , United States Code, water quality is one of the primary issues to be
dealt with in coal mine reclamation. In this case the reclamation bond was inadequate
(producing only about 11% of its appraised value), the mines closed in January, 1991,
Mid-Con took bankruptcy in February, 1992, and the Colorado agency DMG took over
the reclamation in August, 1993. The reclamation work is continuing, however because
its funding from the bankruptcy has not been forthcoming in a timely manner, the work is
still far from complete, it may continue for years (although now scheduled to be completed
in December, 1996), and whether the fiinding will be adequate is far from certain. Only
complete and thorough reclamation which addresses erosion , decreases sediment, and
eliminates metals and toxins from leaching into the water will significantly improve the
degraded quality,of Coal Creek and Crystal River.
Under the law, see C.R.S. 25-8-501, et seq., Mid-Con has had a"discharge permit" from
the Colo. Dept. of Health (Water Quality Control Division) which allows it to discharge
certain pollutants into Coal Creek at certain defined "point sources" provided the
discharges do not exceed certain standards. During the past three years, Pitkin Iron
employees have been obtaining samples from some of the source points, having them
tested, and the results are submitted to the WQCD on a monthly basis. These have shown
some problems with the discharges which Mid-Con states are not"serious". These source
point discharge tests are not intended to and do not evaluate the water quality in Coal
Creek and Crystal River. They do not tesi for most metals, sulfates and other toxins, and
they only measure the sediments and specified pollutants being discharged at the source
points. Since most of the sediments, metals and toxins enter the water at areas other than
the source points, the only way to meaningfully evaluate the water is to comprehensively
test it above and below the mining areas. In the early 1980's the Colorado Dept. of
Wildlife did a study,(water analysis and trout stun) in the Crystal above and below
Restone and Coal Creek above and below the mining areas which concluded:
"7 Of the sixty sir trout shocked from the Crystal River, 91%were
stocked rainbow trout. Except for stations CR-2, CR-3 and CR-9 (those
stations above Redstone) The rest of the shocking locations were virtually
void of naturally occurring trout. ... 9. Coal Creek, Bear,Creek, and Dutch
Creek exhibited very poor water quality with high solids, sulfate and heavy
metals concentrations due to the Mid-Continent Resources Coal Mines.
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