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poor. Regardless of the seepage rates into the sandstone zones, the water quality will be <br />very similar and consistent with the overburden, with a TDS from 2800 to 3500 ppm. <br />2) Due to the low seepage rates, the movement is very slow (400 feet every 10 years). <br />3) The sandstones above the Dakota coals have historically been too poor in quality and too <br />low in flow rates to provide for useful wells. For this reason, no known wells in the <br />vicinity of the mine area have been completed in the Dakota Formation. It is very <br />unlikely that any new wells will be completed in the Dakota Formation in the vicinity <br />since the Brushy Basin Member of the Morrison Formation provides significantly better <br />water quality and flow rate and is located only 160 feet deeper than the Dakota LDx <br />Seam at NHN permit area. <br />4) The local wells are completed in the Brushy Basin Member of the Morrison Formation, <br />which is below the Dakota coals. Although this zone has significantly better quality <br />water, these sandstones are separated from the spoil by shale layers with very low <br />permeabilities, therefore these aquifers cannot be affected by the spoil water. <br />6) Impact of Backfill Water Quality on Surface Water Quality. <br />Spoil Water Quality The chemistry of the water interacting with the spoil is described in the <br />previous section. In order to determine the impact of the spoil water quality on the surface water, <br />it is first necessary to predict the expected quality of the spoil leachate for the NHN Mine. The <br />principal impact from a quality perspective is that any irrigation water will seep rapidly through <br />the spoil, increase in TDS and then discharge through a spoil spring. This is analogous to the old <br />Peabody Nucla Mine and the water quality should be similar to that of SS #1, (see New Horizon <br />#1 Area permit). The NHN spoil spring will issue to a tributary of Tuttle Draw which will impact <br />the quality of Tuttle Draw. <br />Timeframes of Elevated TDS in Spoil Water The time period that these slightly elevated <br />levels of TDS in the spoil water and spoil spring discharges is difficult to calculate. In 1994, the <br />USGS did a detailed study of the impacts of infiltration into spoil at the Seneca II Coal Mine in <br />Routt County, CO. This study is Water Resources Investigations Report 92-4187 titled <br />Hydrology and Geochemistry of a Surface Coal Mine in Northwest Colorado. Lysimeters were <br />installed to measure infiltration rates into the spoil, and samples of inflow water, spoil water and <br />spring discharge was analyzed for the entire area. It was determined that pyrite oxidation was the <br />principal cause of elevated TDS, and that the percent of pyrite in the spoil was the determining <br />factor in the length of time that the TDS would be elevated in the spoil water. A spoil pyrite <br />content of I% by weight, for example, was predicted to fully oxidize in 1600 years (their Table <br />18). TDS levels in the spoil water were approximately 4500 ppm, which was a significant <br />increase over the overburden aquifer water in the area. The coal mine overburden at that site is <br />somewhat younger (upper Cretaceous) in age but is similar in lithologic character to that of the <br />Section 2.05.6(3) Page 26 Sept. 2015 (TR -11) <br />