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~' ~II II~II~II~II~~ II~ sss STATE OF COLORADO Roy Romer, Governor Palti Shwayder, Acting Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. 5. Laboratory Building Denver, Colorado 80222-1530 4210 E. 11th Avenue Phone (303) 692-2000 Denver, Colorado 802 2 0-3 71 6 (303) 691-4700 Apri128, 1995 Ms. Bazbaza L. Pavlik Environmental Protection Spec Division of Minerals and Geology Departrneot of Nattual Resources 1313 Sherman St. Room 215 Denver, CO 80203 ItE: Eastside Coal Company CDPS Permit No.: COG850019 Garfield County Dear Ms. Pavlik: RECEIVEI] MAY 0 5 1995 Division of Minerals 8 Geology I appreciate your allowing me to review the MLRB pemlit for the Eastside Coal Company. It did provide me with a better understanding of the mine and its surroundings. Tn your letter of April 18, you asked that we concur that there will be no fording of an adverse impact from the plugging of the mine or the filling of the mine with mining wastes. The Division is not normally asked to make such a determination, in part because a discharge usually creates an impact. Based on my review it appears that there should not be any additional impact from the plugging provided the discharge is treated. in my review I noted the following: 1.) The seep and spring survey was conducted in August 1983. The flows of the seeps/springs were noted but not their quality. There appears to have been no recent survey required. This limited database will be to the company's disadvantage since it will be presumed that any springs/seeps noted are the result of the filling of the mine. It is suggested that the site be resurveyed to ensure that there are no other seeps/springs prior to plugging and that the survey be repeated periodically until the mine is filled. Monitoring should include metals such as iron and manganese. 2.) The data on metals relative to the quality of the material to be put in the mine is th mg/kg. It does not provide information on the quality of the discharge. The levels appear to be low and not of real concern. [t is suggested that in the future the information be reported in mg/I. 3.) After reviewing the geology and hydrology of the area, I would agree that the water will most likely fill up the mine and discharge through the pipe. The company should be made awaze that they will need an NPDES permit as long as there is a discharge. Release from DMG bond will not result in release from the NPDES permit Is it DMG's plan to have them keep the cturent pond for treatment or will an new smaller pond be built? The NPDES permit for the site will need to be amended dependent on the intended actions. OF' CO~ a/~• ~ r87fi ~ Colorado Department of Public Health and Environment 4.) It is suggested that the monitoring program be expanded to include analysis for the heavy metals for all surface water sampling locations.