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West Elk Mine <br />Groundwater <br />Groundwater data (including baseline information for any new monitoring wells) are also being <br />obtained as presented in Section 2.04.7 and, more specifically, at locations identified on Table 4. <br />The groundwater resources that are monitored or proposed for monitoring are presented in Exhibit <br />71 and shown on Map 1 of Exhibit 71. These include both an upgradient (SOM-3B and SOM-3E) <br />and downgradient (01-11-1 and 03-11-1) monitoring well in both the B and E Seams, respectively. <br />These wells have been constructed so as to be able to assess both background (upgradient) and <br />potentially affected (downgradient) groundwater conditions in the B Seam mining areas, as well as <br />the E Seam mining areas. It is recognized that monitoring well SOM-3E is not upgradient of all <br />proposed mining in the SOD area. However, MCC will construct, as needed, additional upgradient <br />wells and obtain baseline water quality and quantity information for a minimum of one year prior to <br />mining those areas. The downgradient monitoring wells are located so as to be unaffected by <br />mining, yet are appropriately located so as to assess potential mining impacts. These monitoring <br />wells are also located so as to be able to assess the potential migration of groundwater from within <br />the MCC mine workings to locations outside the permit area. <br />Baseline data for groundwater are also being obtained as presented in Section 2.04.7 and, more <br />specifically, on Table 4 of Exhibit 71. The groundwater resources that are monitored or proposed <br />for monitoring are shown on Map 1 of Exhibit 71. <br />Monitoring to determine the hydrologic consequences to groundwater is by seasonal measurements <br />(three times per year to correspond to the start of spring runoff, the peak spring runoff, and the fall <br />low flow) of water level, well water pH, conductivity, and temperature are taken for all monitored <br />wells. Seasonal sampling and analysis of TDS, Fe, and Mn of the facility area wells and alluvial <br />wells shown on Table 5, are also completed. Annually, during the third sampling, a full-suite <br />sample analysis consisting of pH, conductivity, temperature, TDS, calcium, magnesium, sodium, <br />SAR, hardness, bicarbonate, chloride, un-ionized ammonia, nitrate/nitrite, phosphate (PO4 3 as P), <br />sulfate, iron (total and dissolved), manganese (total and dissolved), arsenic, cadmium, lead, <br />mercury, selenium, and zinc. All parameters are analyzed for their dissolved form unless stated <br />otherwise. <br />A seasonal, rather than quarterly or semi-annual well and water quality monitoring schedule was <br />instituted for a variety of reasons. The primary reason for selecting seasonal sampling is that, in the <br />case of groundwater monitoring, these are the only periods of significant changes in groundwater <br />levels, particularly the shallower alluvial/colluvial resources. The groundwater baseline data clearly <br />indicate that there is no reason to attempt to sample these locations in the dead of winter. The <br />adverse conditions encountered in the remote areas of the West Elk Mine lease area severely <br />hamper sampling procedures and influence the collection of meaningful data. As a result, by <br />restricting sampling to the periods of more likely water availability and ensuring sample integrity, <br />MCC will be able to provide meaningful data to the Division while reducing the costs associated <br />with collecting unnecessary data or data that is not meaningful. <br />MCC has selected the water quality parameters above and as outlined in Table 7 for routine <br />measurement because they are most commonly associated with coal mining impact on water <br />quality. Annual, full-suite monitoring will allow MCC to identify possible mining-induced changes <br />2.05-296 Rev. 06105- PR10; 03106- PRIG; 05106- PR10; 05109- TR117