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Page 10 <br />Requirement Regulation Comment <br />20. Prevention of adverse <br />impacts to ground water <br />systems outside permit area <br /> <br />CDRMS regulation <br />4.05.11(1) <br /> <br />A groundwater point of compliance is not established <br />for bedrock aquifers at this site. Compliance with <br />the Basic Standards for ground water, as discussed in <br />Item 10 above, indicates the permittee is likely <br />preventing adverse impacts to ground water quality <br />outside the permit area. All alluvial wells showed <br />seasonal water level fluctuations in response to <br />periods of precipitation or lack thereof. Overburden <br />and coal well water are fluctuating in response to the <br />precipitation recharge, induced ground water flow to <br />the reclaimed mine pits, and in some cases, changes <br />in reservoir water levels. Spoil well water levels <br />indicate that down slope highwall portions of the <br />spoil exhibit significant amounts of saturation. <br /> <br />21. Prevention of impacts to <br />ground water that adversely <br />impact post-mining land use <br /> <br />CDRMS regulation <br />4.05.11(2) <br /> <br />Underground development at the PSCM began <br />during the 2011 water year and stopped soon after <br />and no development work or mining was conducted <br />in the 2016 water year. Due to the premature mining <br />process, prevention of impacts to groundwater cannot <br />be determined as of the date of this review. <br /> <br />22. Minimize disturbance to <br />hydrologic balance within and <br />adjacent to the permit area <br /> <br />CDRMS regulation <br />4.05.1(1) <br /> <br />Exceedances of applicable water quality standards <br />are discussed in the preceding review items. Please <br />see above for details. For surface water, no <br />exceedances of the effluent limitations were reported <br />for the 2016 water year. For groundwater, it has <br />previously been determined that a bedrock <br />groundwater point of compliance well is not <br />necessary. The alluvial groundwater point of <br />compliance well exceeded the selenium standard <br />noted in Table 7 of the AHR. Other exceedances of <br />the basic standards for ground water are discussed in <br />section #18 of this review. Water levels at most <br />wells are within their historic ranges with the one <br />exception discussed in section #19 of this review. <br />The mine is currently idle. <br /> <br />No determination has been made concerning Item no. <br />7 mentioned above regarding elevated Selenium <br />levels. An investigation by the CDPHE and Peabody <br />Sage Creek Mining as to the cause of the elevated <br />selenium measurements is ongoing. Should it be <br />determined that these exceedances are due to impacts <br />permitted under the current mine plan, revisions to <br />the PHC may need to be required. <br /> <br />23. Prevention of material <br />damage to the hydrologic <br />balance outside the permit <br />area <br /> <br />CDRMS regulation <br />4.05.1(1) <br /> <br />Surface water - Note Item No. 22 above <br /> <br />Ground water – Note item 20, above. <br />