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TRAPPER ~INIp6 IpC. III IIII{IIIIIIIIIII 999 Mr. Kent Gorham Colorado Mined Land Reclamation Division 215 Centennial Bldg. 1313 Sherman St. Denver, CO 80203 Dear Kent: June 2, 1992 ~~ ~~® (/ ~~~ ~ `~ 199 /.sec/ M~n~a 2 d/hat~o~ ~pQ, c,~n RE: Trapper response to CMLRD Adequary Review of TR12, the 1991 Annual Report For C-81-010 Trapper has completed its review of the questions and comments posed by the Division in the adequary review (May 4, 1992) of TR-62, the 1991 Annual Report. Following is Trapper's response to questions posed by the Division. Trapper employees addressed all issues for Section 2.0, subsections A, B and C. George Hoffman, Hydro-Engineering, has responded to the concerns in subsection D ---Summary and Dis- cussion of Hydrologic Impacts. Section 2.0 -Annual Hydrology Report (AHR) A. General Comments 1. Wells GP-7 and GP-8 were not plotted on the 1991 AHR map (2 of 2). These wells are distal (3.0 miles) to current operations and are already presented on Map M52. Trapper previously depicted we1Ls in close proximity to current and post mining areas on this map. Trapper will add GP-7 and GP-8 to the 1992 AHR map(s). 2. Trapper shall update Map 52, as requested with all the NPDES site designation numbers rather than the "S-#" notations (surface water sites). Please be advised, however, that all data presented in Section 2.7.4, Premine conditions-surface water and Table 4.8.8 (pages 4-206 to 4-217), Opera- tional monitoring, will no longer have nomenclature that would reflect baseline or early operational names with NPDES numbers. Map M30A has already been changed to the NPDES numbering system but is directly referenced in Section 2.7.4 (page 2-418) to identify these early surface water locations. The first 15 surface water monitoring points were designated with "S#" [o reflect surface vs groundwater (G#) locations. Since then only the NPDES numbering system has been used [o eliminate this double nomenclature problem. Currentty only Table 4.8-11a addresses this double nomenclature issue and identifies monitoring points by both numbering systems. Trapper proposes to identify the remaining six surface water sites (NPDES 001, 002, 003, 005, 006 and 008) first by the NPDES site number leaving the historical baseline number in parenthesis (S#). This will enable a reviewer to cross reference between his- toricallbaseline data and current projected data for water quality parameters submitted with Trapper's permit application and subsequent annual reports. 3. Well site GE-3 was incorrectly referenced on page 2-1. This well monitors the 2nd/3rd White Sand- stone. 4. Trapper will supply the monitoring tables, in the recommended chart format, in the upcoming permit renewal (PR3) to eliminate the wnfusion far Trapper personnel and the CMLRD reviewer. This may include Tables 4.8-12a, 4.8-13, and 4.8-13a as well as any narrative pages that could be affected. P.0. Box 187 Craig, Colorado 81626 (303) 824-4401