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West Elk Mine <br />In the event that a surface crack opens and stays open, surface and spring flows that <br />• encounter relatively permeable zones in the overburden will move downgradient and <br />reemerge as springs with subsequent dischazge into either the Dry Fork or the North Fork. <br />WWE and Messrs. Rold and Dunrud have determined that there is virtually no potential <br />for a surface crack in the permit area to be deep enough to connect with a mine fracture <br />zone. In the extremely unlikely scenario in which this occurs, however, the implications <br />would be minor. If this scenario were to happen to the south of the drainage divide (in the <br />Dry Fork basin} the surface andlor spring flows would be discharged into the mine <br />workings. Waters collected within the mine workings would be treated, if necessary, to <br />comply with the National Pollution Dischazge Elimination System (NPDES) pemrit <br />requirements and pumped through a drill hole back into the Dry Fork basin, as specified <br />in the water augmentation plan (Exhibit 52). Losses within the mine are minor -less than <br />5 percent of the total inflow which could be experienced. The decreed augmentation plan <br />for the Dry Fork basin conservatively provides replacement water for 100 percent of the <br />yield of the basin. The magnimde of replacement water provided by MCC in the Dry <br />Fork/Minnesota Creek basin is orders of magnitude more than will be required, based <br />upon the subsidence evaluation conducted by W WE with Messrs. Rold and Dunrud. <br />• There is a very small risk (WWE has calculated the risk to be less than one percent that <br />one or more of the stock ponds in the Apache Rocks permit revision area could be <br />adversely affected via surface cracks. This risk calculation also holds for the Box Canyon <br />permit revision azea. Pond water could be diverted into locally permeable zones within <br />the overburden where it could: (1) migrate down-dip toward the North Fork or Dry Fork <br />to become part of the tributary alluvial/colluvial contribution of baseflow to the stream <br />system, (2) reappear as an eghemeral seep or spring, or (3) become trapped as storage in <br />an isolated zone within the overburden. If any of these circumstances were to occur, they <br />would render the affected stock pond temporarily useless for retaining surface water. <br />However, the lost water would eventually return to the Dry Fork and/or North Fork. The <br />stock pond embankments could conceivably be effected by surface cracking; although, the <br />probability of this occurring is insignificant. <br />It is important to note that the overburden materials in the permit area contain numerous shale and <br />claystones layers and lenses which tend to undergo plastic deformation under compression, <br />thereby sealing fractures which develop. In addition, the sediment load within surface flows <br />(especially during spring runoffl will tend to fill surface cracks which may develop, thus further <br />reducing the potential to transmit water downward. <br />i <br />2.~$-1 ~8 RevisedJun. 1995 PR06; !/96RN03: Revised May 1999 TR89; Revised Jan. 1998 PR08 <br />