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999 <br />STATE OF COLORADO <br />DIVISION OE MINERALS AND GEOLOGY <br />Department of Natural Resources <br />l li 3 Sherman 51., Room 215 `y` <br /> <br />Denver, Colorado 80203 I <br />~~ <br />r <br />Phone (303) 8663567 III <br />FAX: 13031 fl32-81 f16 <br /> DEPARTMENT OF <br /> NATURAL <br /> RESOURCES <br />To: Dan Mathews Roy Romer <br /> Governor <br />From: Barbara PdVllk lames S. LOChhead <br />Execmrve Director <br /> Michael B Lang <br />Date: October 16, 1995 Division otrermr <br />Re: Roadside Mine TR-20 <br />I have reviewed items 1, 3, 4, 5 and 8 for the above referenced TR <br />and have the following comments: <br />1) The response to this comment is adequate with the <br />exception that the wording on page 203 (3rd paragraph) <br />that references equipment detection limits with regard to <br />effects of mine discharge on the Colorado River makes no <br />sense. Effects of mine discharge on a surface water body <br />are not measured in a laboratory. TDS (and other <br />parameters) are measured, and the impacts to the surface <br />water body are calculated based on the chemical data, the <br />amount of inflow to the surface water body and the flow <br />of the surface water body. The TDS concentrations in the <br />mine discharges at the Roadside Portals Mines are <br />certainly measurable, as evidenced by the concentrations <br />reported in this same paragraph. The operator should <br />clarify this language. <br />3) The response to this comment is adequate. <br />4) PCC states that potentiometric surface maps are not <br />provided, because PCC does "not believe that the Cameo B- <br />Seam or the Rollins Sandstone meet the Division's <br />definition of an aquifer." In the text provided with the <br />TR responses, PCC then states (on page 54) that the <br />Rollins Sandstone "is the best potential aquifer." <br />Later, (on page 60) PCC states that "neither the coal bed <br />nor the Rollins Sandstone meet the definition of an <br />aquifer because there is not sufficient quality or <br />quantity of groundwater for beneficial use." The permit <br />is fraught with contradictions surrounding this issue and <br />should be cleaned up to clarify whether or not these <br />units truly are aquifers. <br />5) The response to this comment is adequate. <br />