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<br />Dan Mathews -3- January 18, 1982 <br />The following concerns arise given the aforementioned observations and <br />statements within the permit application: <br />A. What are the impacts of the mines on irrigated and subirrigated farm lands <br />above and below the permit area? <br />B. What are the impacts of the mines on surface and groundwater right holders <br />located along Ward and Williams Creeks? <br />C. What are the impacts of mine discharges on water quality leaving the mine <br />site and use by downstream irrigators? <br />D. Does Grand Mesa Coal Company have enough water rights to augment losses to <br />senior water right holders? <br />E. Is there sufficient water available in the Colby Domestic Water System to <br />replace lost water to effected well owners? Will Grand Mesa Coal Company pay for <br />the installation of water lines and the water from Colby System? <br />F. The mining activities will increase the permeability of the coal and effected <br />overlying strata. The mine working and effected overlying strata will also be <br />under the hydroloic pressure head of the "Glacial-Alluvial Aquifer". Given these <br />facts, will the mine openings become discharge points for contaminated mine water <br />once the mining operations cease, the pumps are shut-off, and the mine workings <br />fill with water? <br />There is insufficient baseline data within the Permit application to adequately <br />define the existing hydrologic systems and to adequately address the hydrologic <br />consequence of mining. In order to provide the Division with adequate data upon <br />which it must write findings, Grand Mesa Coal Company should: <br />1) Determine the aquifer characteristics (i.e. transmissivity (T) and storativity <br />(S)) for the E and D coal seams, the overlying effected stratum, and the <br />"Glacial-Alluvial Aquifer". This data is needed to determine the effects of <br />mining on groundwater movement, on ground and surface water depletion and on <br />groundwater pollution movement. <br />2) Install more groundwater monitoring wells in the "Glacial-A1luvi al Aquifer". <br />These wells should be spaced such that a detailed piezometric map can be prepared, <br />and the effects of undermining the "Glacial-Alluvial Aquifer" can be assessed. <br />This information is needed to determine the recharge and discharge characteristics <br />of this aquifer and the effect of mining on this aquifer recharge and discharge. <br />3) Collect an adequate 4roundwater baseline. The permit application does not <br />contain a year's worth of groundwater level and quantity data, and therefore, <br />seasonal fluctuations in the quality and quantity of groundwater was not adequately <br />addressed, and there is insufficient baseline data to compare with future ground- <br />water in order to determine the effects of mining on groundwater. The list of <br />water quality parameters which the applicant should monitor quarterly for both <br />surface and groundwater samples is contained in Attachment A. This guideline <br />should be followed unless the applicant can demonstrate that such parameters are <br />not relevant. After a years baseline has been submitted and a complete analysis <br />of the roof, floor, interburden and coal for the E and D seams has been submitted, <br />the Division can reduce the number of parameter analyzed for, the number of sampling <br />Locations and the frequency of sampling. <br />4) Conduct a spring survey. The application does not contain a spring survey. <br />A spring survey should be conducted to determine the discharge areas and dis- <br />charging flows of aquifers in the permit and adjacent areas and to determine the <br />effects of mining on surface water flows through the depletion of spring flows. <br />This spring survey should include the Location of all springs 'in the permit and <br />adjacent areas on a hydrologic map; quarterly field measurements of spring flows, <br />pH, temperature, and electro-conductivity; and information on water rights <br />associated with these springs. <br />