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PAGE 7 An in-depth analysis of water quality is beyond the scope of this analysis. According to available records, water discharged from both mines, while meeting NPDES standards, is not potable. The REGULATIONS OF THE COLORADO MIIVED LAND RECLAMATION BOARD FOR COAL MiN[NG (Section 1.04(14)) define an "aquifer" as "... a zone, stratum, or group of strata acting as a hydraulic unit that can store and transmit water in sufficient quantities for beneficiai use." Because of the sealing effect of the shaly unit that usualiy sepazates the Cameo coal bed(s) from the underlying Rollins Sandstone, and the similar units that isolate the thin, lenticular sandstones that occur above the coal, these three strata groups cannot be considered a hydraulic unit. Taken separately or together, however, none of these strata or groups of strata can be considered an aquifer in accordance with the above-quoted definition. The lack of consistent inflow, regazdless of how large or small, demonstrates that these units do not store water in suffcient"quantities to produce water for baneGcial use;this is further indicated by the extremely iow gpm/acre inflow averages for both mines. While no site-specific data are available, information from two of the same units tested in a more fractured area to the northwest demonstrate the low to extremely low transmissivity of these rocks (the third unit, the Rollins Sandstone, was considered too "dry" to test). Anomalous areas of intense fracturing related to the regional fracture (joint) system in this part of the Piceance basin can and do produce higher water flows, up to 50 gpm in the 5 East Mains of the Roadside South Mine, although nearly half of this amount may originate elsewhere and travel through heaved mine floor to the flow site. However, just three such sites aze present in 1,420 acres • of above-water-level mine workings, or one per 473 acres. And since these are fracture-related flows, the adjacent units cannot be considered aquifers on the basis of these flows alone, since the source of water is unknown. It would appear that, since all significant water flows into and out of the mine are currently being monitored for both quantity and quality, since the transmissivity and water storage capabilities of the Rollins Sandstone and Cameo coal beds and associated rocks aze minimal, and since what little water that is contained, transmitted, or both, by or through these units is unusable for beneficial purposes without treatment, any further monitoring effort is unnecessary. ~(~ J ~'r~`~ 7016 •9• ai AIFG .•. :,^` x Respectfully submitted, 4~~^~ Bruce A. Collins, Ph.D. CPG 7016 February 8, 1996 DISC[A1hiPJi lti, wat wb psPsMmacrudvr wn6 rceped~mdc~earg omdv~b mdpram~a LiEdmNY mde ebb bBrvm ACaQa PhD. ('tle pcymvlyy Pwvdvhwv Cal Caipn I Vc dwr(4 mdu dbdopad b Ym prtpcer hms Omer ewcn Wble the pepvm hr emAe ~ rts,mublc vach rNO, me Scope d Waek fa RPk+6k mm 6ryad Ctet pwided • brtl~dFS..I~T'.~Pf>AleN1[~e~m~OdlbhC CI~Y1~ec ~Wl N1~O01 he ~btrOr eltdiRb®eOe OrrYlRmlCpilYOG lmmm{rlMlrYbYe bldLlmry lO P~ID~C WCO dypk'+blc Ni ils pepaer c+ma cvoch fa tlm r~.rc. of wrh 4u ma he bees pocideE by hsycru oG~ued fiae absrsem, mu w+p sa trrseposbiefammau®la. e(fn a i>•ao+a+bew ~ fioa ~ a mmms d,u Sic rmddme eJmo®d m mveof P+~ m me bqv m me mne dfmal nmmoon M rx~lb8 eri fiul wmnm Ewpc ePv+te v/mm(y d Im lumla peps fw mY d dldmgs fiat atdsec a coap~®LL Cr nw ~mh fimm bmri uc ryp4'+mo ar mmtbmm of me vJavumo rmoad m ds rut Yuhry m m~ rtym WwN be maprtW a dNUd a pmvvmig bwer lp ~wc avoid amt a m m9 rer va fuGv eavpl~ rW eG lad eue epd WvY «gWeuwa a.