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0 <br />_z_ <br />Hydrology - 2.04.7, 2.05.6(3) and 4.05 <br />The hydrology sections of the permit application have been taken from <br />permit applications of adjacent mines. The hydrologic data is sufficient <br />for regional hydrology, but lacks site-specificity. The following concerns <br />must be addressed prior to completing written findings on ground water <br />monitoring, water quality, water rights, alternative water supply, and <br />cumulative hydrologic impacts. <br />1. The letter on page 40 from Ralph V. Kelling of the Montrose <br />Office of the Division of Water Resources to U.S. Steel addresses <br />adjudicated springs and water wells. Rule 2.04.7(2) and 2.05.6(3) <br />require the location of any springs, the measuring of the flow and quality <br />of these springs for seasonal fluctuations, and the determination of <br />the effects of mining on spring flows. Springs were observed in the <br />Hubbard Creek valley on afield trip up the valley. Even though there <br />are no adjudicated springs in the permit and adjacent areas, Blue Ribbon <br />Coal must still conduct a spring survey of the permit and adjacent areas, <br />address the contribution these springs have to surface water supplies, <br />and address the impacts of underground mining on spring flow. Springs <br />should be located on a hydrology map along with all surface water bodies <br />and water wells. The flows of the springs should be measured and field <br />measurements of pH and electro-conductivity should be taken quarterly. <br />2. Water quality monitoring of the alluvial well below Pond lil <br />in the Hubbard Creek valley should consist of quarterly monitoring for <br />all the parameters contained on the attached Baseline Water Quality List <br />(Attachment A) to determine seasonal fluctuations. The number of parameters <br />may be reduced by the Division following the completion of a year's base- <br />line. The resubmittal of permit application information must include <br />at least one complete water quality analysis from this well. <br />3. Blue Ribbon Coal Company has no monitoring well completed in <br />the E-seam nor completed in the stratum overlying the E-seam. The mine <br />is relatively small and the terrain overlying the mine is steep. For <br />these reasons, monitoring wells are impractical and not required by the <br />Division. However, in order to assess the effects of mining on the <br />hydrologic balance - ground water - the applicant should monitor the <br />quantity and quality of mine inflows during mining. The applicant should <br />submit a mine inflow map and a description of the inflows encountered <br />during mining in it's responses to these adequacy questions. The map <br />should be on a full-scale mine workings map, contain the location of <br />each mine inflow or seep and the estimated or measured inflow at each <br />location. The detailed description should include the inflow source <br />(i.e., faults, fractures, seeping floor or roof strata, coal faces, etc.) <br />and observed fluctuations in flow rates. Inflows should be monitored for <br />pH, conductivity and temperature. <br />l~ <br />