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
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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
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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
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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:
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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
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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.
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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
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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.
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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.
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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.
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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.
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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
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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
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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.
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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:
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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.
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