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-~: <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl n( Nalu ral Resources <br />1313 Sherman SL, Room 215 ~{y~~ <br />Denver, Colorado 80203 II <br />Phone: (3031 8663567 <br />FAX: 13031 832-8106 <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />TO: DdII MathBW9 ~ Rny ROmer <br />Governor <br />FrOID: H8rbar8 PBVilk ~ lames S. Lochheari <br />Enecmrve Dueanr <br />Micharl B. Long <br />Date: May 20~ 1996 Division Director <br />Re: Technical Revision No. TR-40 <br />Deaerado Mine (C-81-018) <br />I have reviewed the portion of TR-40 which concerns Western Fuels - <br />Utah's (WFU) proposal to eliminate the biennial sampling <br />requirement for groundwater monitoring wells in Leases C-8424 and <br />C-8425. This memo replaces my memo of Mav 17, 1996. I have since <br />been able to locate more baseline data for the Deserado Mine. My <br />current opinion is stated below: <br />WFU interprets the footnote of Table II.C-11 to mean that <br />a one-time only sampling is required prior to entering <br />the subject Lease areas. The Division does not share <br />this interpretation. The footnote reads, "These holes <br />will be sampled and analyzed for the parameters in Table <br />II.C-8 prior to entering lease (sic) C-8424 and C-8425." <br />It does not discuss the sampling requirements during <br />mining of the subject leaseholds. <br />However, approximately three years of baseline data were <br />collected for the wells in question. I believe that <br />sampling the wells for chemical parameters one time prior <br />to entering the leaseholds plus recommencing water <br />quality sampling in these wells at least one year prior <br />to requesting a final bond release would be sufficient to <br />assess impacts of mining on the groundwater quality. In <br />addition, water level monitoring should continue on a <br />biennial basis, as water level impacts are more likely to <br />occur, and tracking the trend in water levels can be <br />useful for keeping the PHC current. <br />Mr. John J. Mehlhoff of the BLM in Meeker wrote a letter <br />regarding this TR. He said that the elimination of <br />sampling should not occur, because "biennial sampling is <br />minimal to achieve baseline data." You may wish to <br />inform Mr. Mehlhoff that his concerns were taken into <br />consideration, and the decision was made based on the <br />