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<br /> <br />Harry Ranney -2- August 3, 1992 <br />The permit application suggests that water quality in the Lightner Creek and <br />Coal Gulch alluvium is reflected by surface water quality. While that can <br />occur, it is not the usual situation. Alluvial well data can protect the <br />operator from unsubstantiated claims that a mining operation is impacting the <br />alluvium. <br />The Menefee Formation appears to have adequate water to be considered as an <br />aquifer, as evidenced by the presence of water in the drill hole logs. The <br />Fiederspiel - Yeager well, south of the property, appears to draw from the <br />Menefee. <br />The Point Lookout Sandstone could potentially be impacted by rubblization <br />associated with mining. It appears to sit 75-175' below the 'A' coal seam. <br />The Messier well, for which the application proposes a potential impact, <br />appears to be seated in the Point Lookout. Exhibit 3 suggests that the wells <br />located in the alluvium along Coal Gulch may derive their water from the Point <br />Lookout Sandstone. <br />The surface water data found in the permit application is incomplete and was <br />derived from samples taken 5-6 years ago. Full suite analyses, accompanied by <br />flow data should be acquired from all sites. Cherry Creek and Coal Gulch <br />should be monitored at least twice a year, during snowmelt and following a <br />summer storm event. The duration of flow should also be described. Lightner <br />Creek should be monitored for monthly field parameters and quarterly full <br />suite analysis. The analysis shown on Table 10 should indicate flow and date <br />of sampling (March, 1985). <br />Sincerely, <br />Catherine W. Begej <br />Reclamation Specialist <br />CWB/srm <br />4352E <br />