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Tom Gillis -2- November 25, 1981 <br />valley. Even though there are no adjudicated springs in the permit and <br />adjacent areas, Blue Ribbon Coal must still conduct a spring survey of the <br />permit and adjacent areas, address the contribution these springs have to <br />surface water supplies, and address the impacts of underground mining on <br />spring flow. Springs should be Iocated on a hydrology map along with a21 <br />surface water bodies and water wells. The flows of the springs should be <br />measured and field measurements of pH and electro-conductivity should be <br />taken quarterly. <br />2) [dater quality monitoring of the alluvial well below Pond HI in the <br />Hubbard Creek valley should consist of quarterly monitoring for all the <br />parameters contained on the attached Easeline Water Quality List (Attachment <br />A) to determine seasonal fluctuations. The number of parameters may be <br />reduced by the Division following the completion of a year's baseline, The <br />resubmittal of permit application information must include at least one <br />complete water quality analysis from this well. <br />3) Blue Ribbon Coal Company has no monitoring well completed in the E-seam <br />nor completed in the stratum overlying the E-seam. The mine is relatively <br />small and the terrain overlying the mine is steep. For these reasons, <br />monitoring wells are impractical and not required by the Division. However, in <br />order to assess the effects of mining on the hydrologic balance - ground water - <br />the applicant should monitor the quantity and quality of mine inflows during <br />mining. The applicant should submit a mine inflow map and a description of <br />the inflows encountered during mining in it's responses to these adequacy <br />questions. The map should be on a full-scale mine workings map, contain the <br />location of each mine inflow or seep, and the estimated or measured inflow at <br />each location. The detailed description should include the inflow source <br />(i.e., faults, fractures, seeping floor or roof strata, coal faces, etc.) and <br />observed fluctuations in flow rates. Inflows should be monitored for pH, <br />conductivity and temperature. <br />Additionally, Blue Ribbon Coal Company should amend their monitoring program <br />to include a nearly submittal of a mine inflow map, description of mine inflows <br />and mine inflow water chemistry. This monitoring of inflows and reporting <br />of inflow data will satisfy the requirements for the mine to monitor the <br />effects of mining on the hydrologic balance under Rules 2.05.6(3) and <br />4.05.15. <br />4) The Blue Ribbon mine received water rights to 15 gpm of water from <br />the Hubbard Creek water well (Hubbard Creek Decree, Case No. W-3050), and <br />storage rights for water stored in Blue Ribbon P.eservoir No. 1 (Sediment Pond <br />No. I) under Ffubbard Creek Decree, Case No. W-3051. With the four-fold increase <br />in production rate from 50,000 tons/year to 200,000 tons/year, this water right <br />(15 gpm) appears insufficient to cover the increased water required for <br />cooling, dust suppression, fire protection, and domestic uses. Blue Ribbon <br />Coal Company must provide to the Division an analysis of the water requirements <br />of the mine and support facilities in light of it's existing water rights. If <br />the water requirement of the mine exceeds the I~cree, Blue Ribbon Coal Company <br />should apply .Eor additional rights. A water rights analysis is needed to find <br />the applicant in conformance with Rules 2.04.7(3), 2.05.6(3)(a) and 4.OS.IS. <br />If either you or the company have any further questions, please feel free to <br />contact me. <br />/mt f <br />