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-30- <br />value allowable under the qualifying assumptions for use of the <br />modified non-equilibrium technique. In addition, the slope and <br />boundary conditions in the "aquifer" have not been appropriately <br />addressed. Again, insufficient data and explanation are given to <br />recalculate actual drawdown. Fortunately, since no significant <br />resources will be affected this permit term, this concern is not <br />critical to our prediction of material damage. WECC will need to <br />address this item for future permit areas, however. <br />It is projected by the applicant that most springs in the lease area <br />derive their water from the Barren Member of the Mesa Verde Group, and <br />further, that pumping from the mine in the F-seam should not affect <br />aquifers in the zone more than 100 feet above the seam. Although the <br />100-foot estimation is somewhat generalized, this conclusion probably <br />is realistic. Mining will impact springs issuing from the F-seam and <br />beds in the Barren Member immediately overlying it. Interference with <br />springs will be most likely in areas of shallow overburden. In zones <br />of substantial fracturing, springs issuing from beds more than 100 feet <br />above the F-seam may be affected. Finally, if subsidence occurs, all <br />springs overlying excavated areas have some potential for being <br />affected. The reclamation plan, Section 3.2.8.2 .A indicated water is <br />also expected to be derived from below the coal seam. No analysis of <br />the quantities of inflow or impacts of inflows from lower strata on <br />deeper aquifers is presented. <br />The applicant anticipates no degradation of ground water quality during <br />mining. All water developed in the mine is to be used for dust <br />control. The applicant confirms that "any effluent will be treated as <br />necessary to meet water quality standards prior to discharge." The <br />applicant further confirms "there will be no uncontrolled mine water <br />discharge after mining is complete which might otherwise degrade <br />surface streams or ground water" (v.l, -p. 2-349). The mine operation <br />plans indicate (v.l, -p. 3-39) that mine discharges may occur when <br />WECC's water rights are not in priority, but again, that all discharges <br />will be appropriately treated. The operation plan further indicates <br />most water used for dust control will be absorbed on the coal and <br />carried from the mine thereby minimizing the quantity to be treated. <br />Any discharge will be delivered and treated in the sedimentation ponds <br />and discharge as specified in the NPDES permit. In order to assess the <br />quantity, quality, and source of mine inflows, and in order assess the <br />impacts of the mine working on the hydrologic balance within the mine <br />plan adjacent areas, the Division is requiring the following <br />stipulation to the permit: <br />Stipulation No. 6 THE APPLICANT SHALL SUBMIT TO THE DIVISION AN <br />ANNUAL REPORT OF INFLOWS, DISCHARGES AND CONSUMPTION OF WATER WITHIN <br />THE MINE. THIS REPORT IS TO INCLUDE A MINE WORKINGS MAP SHOWING THE <br />LOCATION AND QUANTITY OF INFLOWS, A TABLE KEYED TO THE MINE MAP WHICH <br />SHALL CONTAIN THE SOURCE (I.E. FAULT, FRACTURES, ETC), QUANTITY, <br />DURATION, AND QUALITY (I.E. PH, ELECTRO-CONDUCTIVITY AND TEMPERATURE) <br />OF ALL INFLOWS; A TABLE CONTAINING RECORDS OF WATER DISCHARGED FROM THE <br />MINE, CONSUMED IN THE MINE, AND IMPORTED FOR USE WITHIN THE MINE, A <br />DISCUSSION OF THE WATER BALANCE WITHIN THE MINE, AND FINALLY A <br />PROJECTION OF HYDROLOGIC IMPACTS OF MINING IN THE UPCOMING YEAR. <br />