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,. ~ • - 1 • <br />.. _ <br />-3- <br />The applicant should provide to the Division copies of the mine <br />water quality analyses which were used in calculating the <br />impacts of the Foidel Creek Mine. The 800 mq/1 value for <br />T.D.S. which was used in these calculations is considerably <br />lower than T.D.S. values in mine discharges from other coal ' <br />mines on the western slope. Also,, stagnation of water within <br />the mine upon its closure may produce levels of T.D.S. as much <br />as 10 time higher than in an active mine. <br />The Water Resources Investigation 81-15 (WRI 81-15) which was <br />used by the applicant does not factor in the existance of the <br />Foidel Creek Mine. The existance of an underground coal mine <br />between Foidel and Fish Creek will radically change the <br />projected impacts. Ground water flow lines will be <br />dramatically altered during mining as ground water flows are <br />drawn into the underground mine workings. <br />Also, the post-mining migration of a ground water pollutant <br />plume from the Foidel Creek Mine workings will not resemble the <br />predictions made in WRI 81-15. The mine working will act as <br />conduits for mine water and spoil water flows. This would have <br />the effect of moving the pollutant point source closer to Fish <br />Creek than shown in WRI 81-15. <br />The pollutant plume migration should be recalculated using site <br />specific data and analyses. <br />The applicant should re-evaluate water consumption within the <br />mine. During the mining operation, it is likely that inflow <br />waters will be consumed within the mine and any excess inflow <br />waters will be discharged to the surface system. The <br />underground coal mining operation will require water to cool <br />the mining equipment and water for dust suppression. A portion <br />of water within the mine will be consumed within the mine by <br />evaporative loss in ventilcation air, and by increased water <br />adsorbed on the coal leaving the mine. <br />Any use of mine inflow waters will require the applicant to <br />obtain a well permit from the State Engineer's Office. Also, <br />if the inflow waters are determined by the State Engineer to be <br />tributary water, the applicant will have to prepare an <br />augmentation plan. The applicant's present water tights may be <br />sufficient to develop such an augmentation plan. <br />Surface and Ground Water Monitorinv (2.05.6(3)(b)) and (4.05.13) <br />Several inadequacies were noted in the review of Exhibit l0a <br />"Hydrologic Monitoring Plan". Rule 9.05.13(2)(a)(111) requires <br />the quarterly submittal of surface water monitoring report to <br />the Division (C.M.L.R.D.) which are to include analytical <br />