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HomeMy WebLinkAbout20130689.tiffSTATE OF COLORADO 2013-0689 DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver. Colorado 80203 Phone: (303) 866-3587 FAX: (303) 832-8106 March 1, 2013 Weld County Commissioners County Commissioner 915 10th St Greeley, CO 80631 RECEIVED MAR 0 7 2013 WELD COUNTY COMMISSIONERS COLORADO DIVISION OF RECLAMATION MINING &— SAFETY John W. Hickenlooper Governor Mike King Executive Director Loretta E. Pine. Director Re: Keenesburg Strip Mine (Permit No. C-1981-028) Technical Revision No. 44 (TR-44) Revise Subsurface Water Monitoring Analysis from Quarterly to Semi-annually Dear Sir/Madam: The Division of Reclamation, Mining and Safety hereby issues notice, in accordance with Title 34, Article 33, Section 116, Paragraph 4, of the Colorado Revised Statutes, that on March 1, 2013 an application to revise coal mining operations at the Keenesburg Strip Mine was considered complete for the purposes of filing. The revision was submitted by Coors Energy Company. All review and comment periods as provided in the Act and the Regulations initiate from this date of filing. Coors Energy Company (CEC) submitted Technical Revision 44 (TR-44) to revise the ground water monitoring frequency from quarterly to semi-annually. CEC included in this revision approval letters from the Colorado Department of Public Health and Enviromnent and Weld County Department of Public Health and Environment's Environmental Services Division. There are no proposed changes to permit area, disturbed area or affected area, mineral ownership or surface ownership. No other mine operation procedure changes are proposed in this revision. The Surface coal mining operation is on land located approximately 7 miles North of Keenesburg, Colorado. The permit area is further described as follows: All or portions of Sections 2 and 11, T2N, R64W; and Sections 25 and 36, T3N, R64W; 6th Prime Meridian. The above -mentioned tracts of land are shown on USGS 7.5 minute Quadrangle map of Klug Ranch. The applicant is required to publish notice in a local newspaper that this application has been deemed complete At the time of publication of this notice, the applicant is additionally required to place a copy of this application at the Weld County Clerk and Recorder, 918 10th Street, 2nd Floor, Room 202, Greeley, CO 80631, and at the Division office. For additional information or to Tr/Lb-err, epi r ) Office of Office of Mined Land Reclamation Denver • Grand Junction • Durango L Active and Inactive Mines C •1 1�u,TL Page 2 of 2 provide written continents, contact the Division of Reclamation, Mining and Safety, Room 215, 1313 Sherman Street, Denver, Colorado 80203, (303) 866-3567. In order for us to comply with regulatory time frames, we request that comments be submitted within fifteen (15) days of this letter. If no comments are received by then, we will proceed on the assumption that you have no concerns with, or objections to, the applicant's proposal. Sincerely, Brock F. Bowles Environmental Protection Specialist • • • ENERGY COMPANY March 13.2013 Cits Clerk's Ofllce Keenesburg 1 0vv n hall 140 South Main Ikeenesharg. Colorado 80643 Weld County Clerk & Recorder P.O. Box 459 C ireelec. Colorado 8063_2 Re: Technical Rev ision No. 44 Revision for Subsurface Water Monitoring Analysis schedule from quarted} to semi-annually Keenesburg Mine Keenesburg. Colorado Ladies and Gentlemen: In accordance with the rules and regulation; governing coal mining and reclamation operations in the State of Colorado, public notice and a public reviews period is to he provided NS hell a 1 echnical Res ision to an existing Permit is proposed. Coors Isnergy Company has submitted its I echnical Revision No. 41. requesting approval for a change to the Subsurface Water Monitoring Analysis schedule from quarterly to semi-annually at the Keenesburg Mine near Kcenesbura. Colorado. Notice has been placed in a new spaper closest to the operations site (the It. Lupton Press) and a copy of the proposed Technical Res ision is enclosed. Please place this letter and the enclosed documents in a location where they can he made available to members of the public who wish to review, the contents. Thank you for your assistance. Sincerely. Danny Kipp Chief Reclamation Specialist enclosures • • • 4/.4 _.4 }!v ,ANY February 12, 2013 Brock Bowles, Environmental Protection Specialist Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 RE: Technical Revision No. 44 Revision for Subsurface Water Monitoring Analysis schedule from quarterly to semi-annually Permit No. C-1981-028 (Keenesburg Mine] Dear Mr. Bowles: Coors Energy Company (CEC) is submitting a technical revision (TR-44) application to the Keenesburg Mine permit to revise the Subsurface Water Monitoring Analysis schedule from quarterly to semi-annually. The contents of the TR-44 application include a letter request for Semi -Annual Groundwater Monitoring Frequency from Doty & Associates, LLC dated October 27, 2012, a letter of approval from the Colorado Department of Public Health and Environment dated January 15, 2013, a letter of approval from Weld County Department of Public Health & Environment's Environmental Services Division dated January 16, 2013, proposed Public Notice for TR-44 and revised Page 56 (Permit text). The notice will be placed in the local newspaper when CEC receives concurrence from DRMS as to format and content. Copies of the Technical Revision 44 Application will be delivered to Keenesburg Town Hall and to the Weld County Clerk and Recorder's office for public review once approval is received, and concurrent with publication of the Public Notice. CEC believes that the documentation herein submitted is complete and sufficient for the processing of this Technical Revision No. 44. However, should there be questions, please contact us at 303 944-8166. Sincerely, A Danny Kipp Chief Reclamation Specialist C Ben Doty, Doty & Associates, LLC Benjamin Moline, Manager Water Resources & Real Estate • • • COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY 1313 Sherman Street, Room 215, Denver, Colorado 80203. (303) 866-3567 APPLICATION FORM FOR A REVISION TO A COAL MINING AND RECLAMATION PERMIT This form must be completed and submitted with all requests for minor revisions, as defined in Rule 1.04(73), technical revisions, as defined in Rule 1.04(136), and permit revisions, as defined in Rule 1.04(90). All revisions are to address the requirements of Rule 2.08.4. Three (3) copies of the revision, including maps, must be submitted in order for it to be complete. All revisions are to be formatted so they can be inserted into the tables and/or figures, with a revised table of contents, if necessary. in the lower right corner of each revision page. A cover letter to revision and reference the specific permit sections being revised. For federal mines, a copy of the revision application must be submitted to all agencies on the federal mailing list (except OSM) at the same time the application is submitted to the Division, and proor of distribution must be submitted to the Division along with the application. Copies of revision pages modified during the review process must be distributed in the same manner, along with proof of distribution. Proof of distribution must be submitted prior to implementation of the revision. Permit No.: C - 1 9X / - C / 6 Permittee: • Street: • City: State: Coors Energy Company permit to replace the revised sections, maps, The revision submittal date should be printed the revision should explain the nature of the Date: 02 / 12 / 13 P.O. Box 467 Golden Co Zip Code: 80402 Brief Description of Revision: Revise the Subsurface Water Monitoring Analysis from quarterly to semi-annually Public Notice Attached: Yes✓ No Bond Increase: Yes ,NoJ✓ Proposed Change in: Permit Area - Disturbed (+/-) _ _ Q 0 Acres Permit (+/-) _ _ O. 0 Acres Affected (+/-) _ _ 0, 0 Acres Mineral Ownership - Mineral Private (+/-) _ _ 0. 0 Acres Mineral Federal (+/-) _ 0. 0 Acres (Required for PRs and TRs) Federal Non -Federal Mine Surface Ownership - Private Land (+/-) _ _ 0 . 0 Acres Federal Land (+/-) _ _ 0 0 Acres State Land (+/-). _ 0. 0 Acres Mineral State (+/-) _ _ 0 0 Acres • • • DOTY & ASSOCIATES. LLC ENVIRONMENTAL. GROL NDAV AT[R AND WASTE MANAGIiMi N I ENGINEERS 1440 HRI(KI'ARD ROAD SU ITL I GOI DEN. COLORADO 80403-8054 VOICH'. (303)279-9181 FAX'. (3031?79-9IX6 Mr. Douglas M. Ikenberry, P.E. Colorado Dept. of Public Health & Environment Mail Code HMWMD-SWIM-B2 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 hup_ v.'.V .doiticnycnm bpdmy¢r dotvenu. con) October 27, 2012 302-17 Subject: Request for Semi -Annual Groundwater Monitoring Frequency Keenesburg Disposal Site Dear Mr. Ikenberry: This letter requests that the groundwater monitoring frequency at the above referenced site be changed to semi-annual. This is essentially a restatement and expansion of our earlier request on this topic (Doty, 2008). DESCRIPTION OF OPERATION As you may recall, the Keenesburg facility was a surface coal mine that began operating in 1981. The mine closed in the late 1980s and the pit was backfilled to nearly original grade with stockpiled overburden material. Since 1987, ash from the coal-fired power plant at the Coors facility in Golden has been hauled to the site to provide additional backfill needed to complete the reclamation process. This use of ash was interpreted as waste disposal and brought the facility under regulation by your Division. The approved operations plan, as modified, also allows the facility to accept waste rock from other mines on a case -by -case basis and the demolition and disposal of on -site facilities such as the shop/office building. Assuming constant progress, backfilling with the approved materials is expected to continue through approximately 2020. Ash is placed in disposal cells that are lined with clayey overburden material and are a minimum of four feet above the water table. The ash is covered routinely as it is placed and, when areas approach final grade, a final cover is placed that consists of six feet of clayey material. Finally, a two foot thick layer of topsand is placed over the final cover and seeded to establish vegetation that is self-supporting under ambient precipitation conditions. In our opinion, there are three characteristics of the operation with important implications relative to the frequency of groundwater monitoring. • • • Mr. Douglas M. Ikenberry, P.E. Page 2 October 27, 2012 Doty & Associates, LLC The materials being placed are effectively isolated from the environment by a very conservative disposal cell design. This means that releases (if any) are likely to be slow and of small quantity. Because the materials being placed are from only a few limited sources, they are very chemically consistent. Thus, the chemistry of facility releases (if any) should also be consistent over time. 3. The materials being placed are relatively inert (both chemically and biologically). This means that leaching should be minimal and that releases (if any) should not be highly concentrated. Sparingly concentrated releases pose less threat to the environment and to downstream receptors. GROUNDWATER HYDROLOGY & USE Following discussions in the groundwater monitoring plan (Doty, 1998), the uppermost aquifer consists of clayey backfill, undisturbed bedrock (primarily silty claystone), and the Ennis Draw alluvium northeast of the site. These materials form a single interconnected, unconfined hydrologic system. The clayey backfill and undisturbed bedrock are the least permeable portion of the system and these materials have roughly equal saturated hydraulic conductivities of approximately 3x10-5 centimeters per second (cm/s) or lower. The alluvium, on the other hand, is more permeable, having a conductivity of 1x10° cm/s or higher. Prior to mining, flow in the overburden was to the northeast toward the alluvium. Flow in the alluvium is to the northwest following the alignment of Ennis Draw. When the pit was open to expose the coal at an average depth of approximately 90 feet, groundwater flow was inward toward the excavation. After the pit was backfilled with overburden, flow remained inward in response to the existing drawdown at the pit perimeter and the moisture demand of the less than saturated overburden backfill. Because of the relatively low hydraulic conductivity of the surrounding materials, the relatively large quantity of overburden backfill and the low infiltration recharge due to the arid climate, inward flow (resaturation of the backfill) is still occurring. An analysis presented in the groundwater monitoring plan (Doty, 1998) showed that this long-term recovery of the groundwater system was consistent with hydrologic conditions. The most recent evaluation of the rate and direction of groundwater flow (using December 2011 data) indicates that the flow system continues to be dominated by resaturation of the backfill. These data imply that the maximum groundwater flow velocity is toward the area being resaturated and it is estimated to be approximately 1 foot per year. The gradient away from the facility toward Ennis Draw is approximately 0.005 feet per foot and the flow velocity is on the order of 0.5 feet per year. Also as discussed in the groundwater monitoring plan, there is very limited use of groundwater in the site vicinity. A recent review of the State Engineer's website indicates • Mr. Douglas M. Ikenberry, P.E. Page 3 October 27, 2012 Doty & Associates, LLC that the closest off -site well is approximately one mile from the former mine limits. The well is completed in shallow bedrock and is used for stock watering. The well is generally downgradient of the facility and is downgradient of monitoring well DH -96. There is no residential development and essentially no use of surface water in the general area. The key site characteristics from the point of view of groundwater monitoring frequency are as follows. Groundwater flow from the site to off -site areas is extremely slow (about 0.5 feet per year). This means that releases (if any) would only travel a fraction of a foot farther between monitoring events if the frequency is reduced. 2. The geologic materials are only sparingly permeable and, as a result, have not been developed as a groundwater resource. Therefore, there are essentially no receptors in the vicinity of the site and risks to receptors are not increased by a reduced monitoring frequency. GROUNDWATER MONITORING RESULTS Groundwater monitoring began at the site prior to the commencement of mining in 1981 to support baseline environmental characterization. Although groundwater monitoring was on -going in accordance with the Division of Reclamation, Mining & Safety (DRMS) regulations, a revised groundwater monitoring plan was developed through negotiation with your Division in 1998 (Doty, 1998) such that it met both the requirements of your regulations and those of DRMS. Since that time, we have been statistically evaluating the groundwater monitoring results on a quarterly basis using a database beginning in March 1993 for five wells (79 samples each) and in December 1999 for a newer well (51 samples). A total of 446 quarterly samples have been collected from the six wells since March 1993 (almost 20 years of quarterly samples). During this period, the chemistry of the groundwater samples has been quite consistent. There have been only two significant increases indicated by the tolerance limit based statistical evaluations. The first involved dissolved iron in two wells in 2001 that we suggested was caused by changed laboratory procedures and reporting limits (Doty, 2001). Although you did not agree with our reasoning at the time, we believe our position is supported by the fact that iron has since been essentially non -detectable in these wells, albeit at a higher reporting limit. The other significant increase involved manganese in a well completed in the pit backfill (well SMW-2). Between March 1993 and September 2012, manganese in the SMW-2 samples has increased from about 0.3 to 0.6 milligrams per liter and a statistically significant increase was indicated in 2004. In Doty (2005), we demonstrated that the increased manganese most likely was caused by dissolution of manganese from the backfilled overburden as it gradually resaturates following cessation of mining and not by a release from the ash backfill. • • • Mr. Douglas M. Ikenberry, P.E. Page 4 October 27, 2012 Doty & Associates, LLC Key conclusions that can be drawn from the monitoring conducted to -date are as follows. Background has been adequately established for statistical analyses. 2. Other than equilibration with the chemistry of the comminuted overburden backfill, there have been no significant groundwater quality changes and certainly no changes indicative of a release from the disposal facility. SUMMARY & CONCLUSIONS In our opinion, a reduced sampling frequency is appropriate and justifiable for this site. 1. The regulatory requirement that background be established through collection of a minimum of eight quarterly samples has been satisfied. 2. There is no evidence of a release from the ash backfill areas and constituent concentrations have been quite stable during the period of record. 3. Rapid transport of dissolved contaminants associated with a release (that might otherwise warrant more frequent monitoring) is highly unlikely given the low hydraulic conductivity of the subsurface materials and the relatively slow groundwater flow velocity. The site poses little risk because the materials being placed are limited to a few well characterized relatively inert materials and they are effectively isolated from the environment by the disposal cell design. There are essentially no downstream receptors due to the low population density and very limited use of shallow groundwater in the area. Therefore, we request that the groundwater monitoring frequency for this facility be changed to semi-annual, as allowed at B4(B) of the solid waste regulations. LOGISTICAL CONSIDERATIONS Because the Keenesburg site is also regulated under the mining rules, a technical revision to the reclamation permit will be prepared and submitted to DRMS after receipt of approval of the monitoring schedule change from your Division and from Weld County. We will continue the currently approved quarterly monitoring program until such time as we have approvals from your Division, Weld County and DRMS. In addition, after all approvals have been received, we will notify the three regulatory groups of our schedule for implementing semi-annual monitoring. • • Mr. Douglas M. Ikenberry, P.E. Page 5 October 27, 2012 Doty & Associates, LLC I trust that foregoing is complete enough for your review and approval. Please call if you have any questions or need additional information. Your prompt attention to this matter is much appreciated. Sincerely, DOTY & ASSOCIATES, LLC Benjamin P. Doty, P.E. cc: Mr. Roger Doak, CDPHE Mr. Trevor Jiricek, Weld County Mr. Troy Swain, Weld County Mr. Brock Bowles, DRMS Mr. Donald W. MacDonald, Coors Energy Company REFERENCES Doty, 1998, Ground -Water Monitoring Plan, Keenesburg Ash Disposal Site, Revision 2.0, prepared for Coors Energy Company, Doty & Associates Project No. 302-15, October 1. Doty, 2001, Alternative Source Demonstration, Statistically Significant Increase Over Background, Iron in AMW-1 and SMW-2 Samples, Keenesburg Disposal Site, letter to Mr. Douglas M. Ikenberry, P.E., Colorado Department of Public Health & Environment, from B.P. Doty, Doty & Associates Project No. 302-17, June 14. Doty, 2005, Alternate Source Demonstration, Statistically Significant Increase over Background, Manganese in SMW-2, Fourth Quarter 2004, Keenesburg Disposal Facility, Coors Energy Company, letter to Mr. Douglas M. Ikenberry, P.E., Colorado Department of Public Health & Environment, from B.P. Doty, Doty & Associates Project No. 302-17, April 8. Doty, 2008, Request for Revised Ground -Water Monitoring Frequency, Keenesburg Disposal Site, letter to Mr. Douglas M. Ikenberry, P.E., Colorado Department of Public Health & Environment, from B.P. Doty, Doty & Associates Project No. 302- 17, June 3. • • • t- COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the hearth and environment of the people of Colorado 4300 Cherry Creek Dr S. Laboratory Services Division Denver, Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230.6928 Located in Glendale, Coiorado (303) 692-3090 hno://www.cdpbe.staie.co.us iwww.cdpbe.state.co.us January 15. 20I3 Mr. Donald MacDonald Coors Energy Company Y.U. Box 467 Golden, CO 80402 Colorado Department of Public I lo,dtlt and Etivironntent RE: Approval with Conditions of Request for Semi -Annual Groundwater Monitoring Frequency (Doty & Associates, i.,LC letter dated October 27, 2012) Keenesburg Ash Disposal Facility Dear Mr. MacDonald, The Hazardous Materials and Waste Management Division (Division) of the Colorado Department of Public Health and Environment reviewed the above referenced Request for Semi -Annual Groundwater Monitoring Frequency (Doty & Associates, LI,C letter dated October 27, 2012). Additionally, the Division reviewed a site map (dated January 21, 2012) attached to Ben Doty's January 4.2013 e-mail that depicts the potentiometric surface of the groundwater table at the site on December 11. 201 1. In consultation with the Weld County Department of Public Health and Environment, the Division approves the Keeneshurg Ash Disposal Facility request to conduct semi-annual groundwater monitoring at the site with the following conditions: I ) The Division reserves the right to rescind our approval based on changing site conditions. 2) Semi-annual groundwater monitoring shall commence in the second quarter of 2013. 3) A map that depicts the potentiometric surface of the groundwater table as well as other pertinent site features and information (as presented on the attached figure) associated with each fourth quarter groundwater sampling event shall be submitted to the Division and Weld County within ninety (90) calendar days of the sampling event. In closing, the Division is authorized to bill for its review of technical submittals pursuant to Section 1.7 of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2. An invoice for the Division's review of the above referenced documentation will be sent under separate cover. • • Mr. Donald MacDonald January E:. 20I 3 Page 2 of 2 Please contact me at 303-692-3389 if you have any yucstlo s. Sine re:y. Douglas M. lkenberry Solid Waste and Material Management t?nit Solid and Hazardous Waste Program Cc: Bea i)oty. P.l... Doty and Associates. LLC Troy S'‘ain. Weld County Department of Public Health and Environment Attachment ELI': SW WI.l)COO •1_ r 1 FIGURE 3 POTENT!OMETR C SURFACE ' is V� ` \ t `--- ?� l \ '� ,'� "\ \' } �ERMlT •�••� , f "BOUNDARY • •••• \ ,OU'\ AMW-1 e".• 1� ' 4766.2 \ \ 48645- v t, • q IT. 4 ''-- g) ` 6i$ '�jo, - AMW-2 4770.4 4-� ii'APIT: , i8 4.4 -.` \'r 4.7'9 • , SMW-2 `\ 4759.0 O \•l • OH -96 1, ! . 4756.2 P tit 1 1 I. r '------, 6 ;_ 1.,.."17. -- 476/`1+ /' 'i• �• a. Cfi', r`\ . " rte• , •\\t 80� tD RECTION OF FLOW WATER LEVELS MEASURED ON 12'11:'2004 4798.5_ 0 ti 1 A 750 n 1500 SCALE IN FEET DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 1555 North 17th Avenue Greeley, CO 80631 Web: www.weldhealth.orq Health Administration Public Health & Clinical Vital Records Services Tele: 970.3046410 Tele: 970304.6420 Fax: 970.304.6412 Fax. 970 304 6416 Public Health Environmental Health Communication, Emergency Preparedness Services Education E Planning & Response Tele. 970.304.6415 Tele. 970 304.6470 Tele. 970 304 6420 Fax: 970.304.6411 Fax: 970.3045452 Fax 970.304 6469 Our vision Together with the communities we serve, we are working to make Weld County the healthiest place to live, leem, work and play January 16, 2013 Donald MacDonald Coors Energy Company PO Box 467 Golden, CO 80402 Coors Energy Services — Keenesburg Ash Monofill and Reclamation Site Approval of Groundwater Monitoring Reduced Sampling Frequency Request Dear Mr. MacDonald: The Weld County Department of Public Health & Environment's Environmental Services Division hereby approves the request dated October 27, 2012 to reduce the groundwater monitoring frequency from quarterly to semi-annual, submitted by Doty & Associates LLC on behalf of Coors Energy Services for the ash disposal monofill, located at 13495 Weld County Road 61, permitted as a waste disposal facility by Weld County under Certificate of Designation and Use By Special Review Permit Number 1160 & 386. If you have any questions regarding this inspection, please contact me at 304-6415, extension 2219. Sincerely, Troy E. Swain EH Program Coordinator Environmental Health Services cc: Doug Ikenberry, CDPHE-HMWMD (via e-mail) Tom Parko. Director - Weld County Department of Planning Services (via e-mail) PUBLIC NOTICE • Coors Energy Company (CEC), P.O. Box 467, Golden, CO 80402, (303) 944 -8166, has applied to the Colorado Division of Reclamation, Mining & Safety (CDRMS) for a technical revision to change the Subsurface Water Monitoring Analysis schedule from quarterly to semi-annually. Coors Energy Company owns and operates the Keeneshurg Mine under the current CDRMS Permit C- 1981-028. The Keeneshurg Mine is located 7 miles north of Keeneshurg, Colorado, and is accessed by Weld County Road 59. The USGS 7.5 -minute quadrangle maps "Klug Ranch" and "Tampa" contain the described operation. The permitted area is portions of Sections 25 and 36, T3N- R64W, 6'h Principal Meridian, Weld County, Colorado. • • Copies of the application may be viewed at the Town Hall 140 S. Main, Keeneshurg, Colorado; at the Weld County Clerk and Recorder's Office, 1402 N. 17th Ave., Greeley, Colorado; and at the Colorado Division of Reclamation, Mining and Safety, 1313 Sherman Street, Room 215. Denver, Colorado 80203, (303) 866-3567. Copies of the Permit Application Package are on file at the Keeneshurg Mine Site and at the offices of the Colorado Division of Reclamation, Mining & Safety. Alt comments, objections, and requests must be submitted in writing to the Colorado Division of Reclamation, Mining & Safety at the above address. The public comment period extends for ten days following the date of publication of this notice. Published in the Ft. Lupton Press on February , 2013 Subsurface Water Monitoring and Analysis Since the initiation of a formal ground -water sampling program in January. 1982. subsurface water quality information has been collected from monitor wells at the Keenesburg Mine. The present ground -water monitoring program provides information which can he compared to the earlier baseline conditions relative to groundwater movement and quality in the formerly active operations areas (now used for ash disposal as part of the reclamation effort). The results obtained from data collected in the field and from comprehensive water quality analysis indicate that surface and ground -water quality has not been significantly impacted by the mining operation, nor altered from the natural pre - mining condition. In addition, regional ground -water movement patterns have not been significantly influenced, altered or interrupted by the mining or reclamation activities. The subsurface water wells arc monitored on a semi-annual basis by Coors Energy Company employees. The six (6) wells presently monitored are: • 1) FPW 2) DH -122 3) Dll-96 4) AM W-1 5) SMW-2 (i) AMW-2 Note: This is also the order in which the wells are sampled, based on historic and present salinity levels. "Analysis" includes both field and laboratory work performed on samples taken from all wells. The sampling procedure to be used is described herein: The order of sampling of the wells is determined based on the historical salinity level of each of the wells relative to the others. The well with the lowest salinity level is sampled first, followed by the others, in increasing value. This order will protect each well against possible data contamination from a higher salinity well. Following a visual examination of the physical condition of the surface area around the well casing. and the casing itself for damage or unusual conditions, the cap is removed and the static water level is measured, from the top of the well casing, and recorded. A one (1) liter sample hailer is used to remove five (5) bailer volumes of water. The fifth bailer volume is used to rinse the field sample containers. A sixth bailer volume is used to fill the field sample container. The field sample is then analyzed and values arc recorded for temperature, pH, and electrical conductivity. • 56 Hello