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maintained in the channels of the two tributaries during the months of August <br />and September near their confluences with Fish Creek. The surface effects of <br />water discharged from the mine on the downstream AVF locations is restricted <br />to the months of June and July. Subsurface effects are expected to <br />predominate in August and September. <br />Water quality constituents of concern to the AVF identified on Fish Creek <br />include trace metals, sulfate, and TDS. An evaluation of concentration levels <br />present in the mine discharge indicate TDS to be the constituent most likely <br />to place a restriction on the quality of irrigation water. Rule 2.06.8(5)(b) <br />identifies material damage as increases in electroconductivity to levels above <br />a threshold value at which crop yields decrease. The relationship between <br />electroconductivity and TDS has been demonstrated level by Peabody Coal <br />Company, in the permit application. <br />The operator has submitted an analysis based on a mass-balance loading of TDS <br />in Fish Creek. Concentrations of TDS in mine effluent were the maximum values <br />from Spoils Spring Number 1 in the Cow Camp Creek drainage. Mean flow values <br />for June and July were used for Cow Camp Creek, Bond Creek, and an upstream <br />location on Fish Creek in the calculations. Results indicated significant <br />dilution would take place and maximum expected TDS concentrations of 607 mg/1 <br />were expected in Fish Creek below the mine. <br />The maximum TDS level projected would correspond to a conductivity of less <br />than 1 mmho/cm. A conservative estimate of the relationship between <br />irrigation water salinity and root zone soil salinity, as referenced in <br />USDA Handbook 60, is 1 to 1.5, respectively. Thus, irrigation water applied <br />with a specific conductance of 1 mmho/cm would result in root zone soil water <br />with a specific conductance of 1.5 mmho/cm. No decrease in production of any <br />of the species identified in data submitted by the operator would be expected <br />unless the conductivity of the irrigation water were to exceed 1 mnho/cm. No <br />significant decreases in productivity would occur unless root zone soil water <br />salinity were to exceed 1.5 mmho/cm. <br />Given the limited effect of Seneca II Mine discharge on Fish Creek surface <br />water quality, it is deduced that alluvial ground water quality should not be <br />significantly impaired. Recharge of the Fish Creek alluvium from the Cow Camp <br />and Bond Creek tributaries would be expected to be minimal compared to <br />upstream contributions. Sub-irrigation would be expected to be less affected <br />by mine discharge than irrigation using surface waters. A conservative <br />estimate of the expected effect of mining indicates that no material damage <br />would resul t. <br />The following findings are in order for the alluvial valley floor known <br />as Fish Creek: <br />1. The Division finds that activities proposed by the applicant will <br />not interrupt, discontinue, or preclude farming on the alluvial <br />valley floors that are irrigated or naturally sub-irrigated. <br />(4.24.3(1)). <br />2. The proposed activities will not materially damage the quantity or <br />quality of water in the surface or ground water system described <br />above. (4.24.3(3) and 2.06.8(5)(a)gii)). <br />3. The proposed activities will comply with the requirements of the Act <br />and the Regulations with respect to alluvial valley floors. <br />(2.06.8(5)9a)(iii)). <br />-35- <br />