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~ ~ -3- The Water Resources Investigation 81-15 (WRI 81-15) which was used by the applicant does not factor in the existance of the Foidel Creek Mine. The existance of an underground coal mine between Foidel and Fish Creek will radically change the projected impacts. Ground water flow lines will be dramatically altered during mining as ground water flows are drawn into the underground mine workings. Also, the post-mining migration of a ground water pollutant plume from the Foidel Creek Mine workings will not resemble the predictions made in WRI 81-15. The mine working will act as conduits for mine water and spoil water flows. This would have the effect of moving the pollutant point source closer to Fish Creek than shown in WRI 81-15. The pollutant plume migration should be recalculated using site specific data and analyses. The applicant should re-evaluate water consumption within the mine. During the mining operation, it is likely that inflow waters will be consumed within the mine and any excess inflow waters will be discharged to the surface system. The underground coal mining operation will require water to cool the mining equipment and water for dust suppression. A portion of water within the mine will be consumed within the mine by evaporative loss in ventilation air, and by increased water adsorbed on the coal leaving the mine. Any use of mine inflow waters will require the applicant to obtain a well permit from the State Engineer's Uffice. Also, if the inflow waters are determined by the State Engineer to be tributary water, the applicant will have to prepare an augmentation plan. The applicant's present water rights may be sufficient to develop such an augmentation plan. Surface and Ground Water Monitoring (2.05.6(3)(b)) and (4.05.13) Several inadequacies were noted in the review of Exhibit l0a "Hydrologic Monitoring Plan". Rule 4.05.13(2)(a)(iii) requires the quarterly Z submittal of surface water monitoring report to the Division (C.M.L.R.D.) which are to include analytical results from each surface water sample (stream and NPDES) taken during the quarter. The applicant should, therefore, ammend the monitoring plan to reflect quarterly, not annual, {,~~`;~ G:_ submittal of surface water data. Ground water data should also be ~:~,~ ,,~ submitted on a quarterly basis. Quarterly submittal of monitoring data ~o is consistant with reporting requirements placed on mining permits since ~~•,,FFebruary of 1981. •--.,. The annual mine inflow study should also include a discussion of the source of each inflow (i.e. from fault, fractured roof, abandoned exploration drill hole, weeping roof, weeping coal face, roof bolt holes, seal to mined out panel area, etc.).