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.. ~oR • III IIIIIIIIIIIIIIII • ~~'~ <br />~r '`('-'~" so DEPARTMENT OF NATURAL RESOURCES <br />* .~ ~ ,1 * David H. Getches, Executive Director <br />• Y\Y~"~~l/ ' MINED LAND RECLAMATION DIVISION <br />'~ X876 a DAVID C. SHELTO N, Director __ <br />Richard D. Lamm <br />Governor <br />December 24, 1986 <br />Ms. Claire Semmer <br />Environmental Specialist <br />Twentymile Coal Company <br />Box 748 <br />Oak Creek, Colorado 80467 <br />Re: Preliminary Adequacy Comments on Technical Revision No. 1, Hydrologic <br />Monitoring Plan, Fish Creek Loadout, C-81-036 <br />Dear Ms. Semmer: <br />The staff evaluation of T.R. 1 has taken place. The proposed hydrologic <br />monitoring plan for the Fish Creek Loadout facility proposes the following <br />changes: the elimination of monitoring at two surface water sites and five <br />alluvial sites; a decrease in parameters being monitored; and a reduction in <br />the frequency of furl suite monitoring at surface water sites from twenty-four <br />(24) times per year to four (4) times per year. The Division has concerns <br />regarding the first two changes which are discussed below. The Division <br />accepts the proposed reduction on the frequency of monitoring surface water <br />sites with reservations. Quarterly full suite monitoring is far less likely <br />to provide data which is representative of seasonal changes in water quality <br />than monthly monitoring. More frequent monitoring would provide better <br />definition of the mean and extreme water quality parameters found at each <br />site. The reduction in frequency means that anomalous values will have a <br />greater effect on the mean. If this becomes a problem, we may require more <br />frequent monitoring. <br />Please address the following Divisional concerns: <br />~~~~ 1. The Division would like to see an evaluation made of data collected to <br />date at the series wells across the Fish Creek alluvium. Submit graphic <br />analyses of the alluvial water table on a seasonal basis, as well as an <br />interpretation of the results. The original objective for monitoring at <br />this site was to identify the seasonal recharge-discharge interactions <br />between Fish Creek and the alluvium in anticipation of drawdowns from the <br />underground mine. (It appears that these sites are associated with the <br />Fish Creek Tipple permit due to the sites' proximity to the Loadout.) <br />Following the Division's review of the analysis an evaluation wi]l be <br />made about the suitability of removing those sites from the monitoring <br />program. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />