2019-04-19_REVISION - C1981019 (6)

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RULE 4 PERFORMANCE STANDARDS Rule 4 Performance Standards 4-17 Revision Date: 4/29/19 Revision No.: MR-201 Based on the above, the Colowyo Mine is located on both a topographic and structural high. Thus, these highs cause the mined units of the Colowyo Mine to be above any significant recharge source, e.g., surface water. This is because the bottoms of the pits are at an elevation higher than the elevation of the surface water in the creeks. Only when the units are at an elevation lower than the valleys does any significant recharge occur. Thus, the only source of recharge for the mined units in the pit areas of the Colowyo Mine is precipitation. Precipitation is less than 22 inches (on average) per year. Evaporation rates approach 30 inches per year, with recharge rates in the Goodspring Creek and Taylor Creek basins being less than 0.35 inches per year. In addition, any surface water/precipitation on this topographic high has to percolate through the clayey soils, prevalent in the area of the Colowyo Mine, into the underlying bedrock. Any water that recharges the bedrock units tends to accumulate along unit contacts since these tend to be areas of least flow resistance. This is exhibited in the highwall of both pits of the Colowyo Mine, where any discharge is easily seen as issuing primarily from these contacts and has been the case since 1981. Any ground water that has been discharged from the mine highwall has been found to evaporate from the pit floor or be consumed by pit highwall. Past hydrological studies also reveal the mined units tend to have low permeabilities (even the sandstones) and do not allow for large water movement, even if the ground water is present. This is also the case where the ground water is under confined or unconfined conditions (i.e. below the elevation of the valley bottoms). If any ground water does percolate vertically through the discordant geologic units, it encounters a tonstein bed near the base of the Williams Fork Formation. This bed is approximately 150 feet above the top of the Trout Creek Sandstone and is approximately 400 feet below the bottom of the active pits. The tonstein bed has an approximate thickness of 2.5 feet. Permeability tests of this material show it has permeabilities greater than 1x10- 10 centimeters per second. Thus, this bed is an effective aquiclude and prevents downward movement of any ground water to the underlying Trout Creek Sandstone. Water Quality The quality of the water in the area of the Colowyo Mine has been rated as poor by the USGS and designated for limited agricultural use. Since USGS testing in 1978, no water quality analysis performed at monitoring points at the Colowyo Mine have shown any significant difference in water quality compared with what the initial USGS work. The water is slightly saline, alkaline and definitely classified as ‘hard’ water. This can be seen in the water quality measurements for total dissolved solids (TDS) and electrical conductivity (eC). Both TDS and eC exceed the EPA secondary drinking water standards. Since the water is alkaline, the pH is above 7, but rarely exceeding 8.4. Concentrations of heavy metals rarely exceed health limits, as stated in the USGS report. This has also been backed up by the shallow ground water monitoring performed since the Colowyo Mine began operation.