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Lan ha ~he~~s -3- January 16, 196? <br />The folIowiny concerns arise given the afozemen tinned observations and <br />statements within the permit application: <br /> <br />1 <br /> <br /> <br />t <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />1 <br /> <br /> <br />A. A'hat are the impacts of the mines on irrigated and subirrigated farm lands <br />above and below the permit area? <br />B. tJhat are the impacts of the mines on surface and groundwater right holders <br />located along ward and Williams CreeY,s? <br />C. What are the impacts of mine discharges on water quality leaving the mine <br />site and use by doc.•nstream irrigators? <br />D. Does Crand Mesa Coal Company have enough water rights to aucment.iosses to <br />senior water right holders? <br />E. Is there sufficient water available in the Colby Domestic water System to <br />replace lost water to effected well owners? hill Grand ,lesa Coal Company pay for <br />the installation of water Lines and the water from Colby Sustem? <br />F. The minima activities will increase the permeabilitu of the coal and effected <br />overlying strata. The mine working and effected overlying strata will also be <br />under the hydroloic pressure head of the "Glacial-Alluvial Aquifer". ~Civen these <br />facts, will the mine openings become discharge points for contaminated r,?ne water <br />once the mining operations cease, the pumps are shut-off, and the nine wozY.ings <br />fi 11 wi th water? <br />There is insufficient baseline data N•ithir, the Permit application to adecuately <br />define the existing hydrologic systems and to adequately address the hydrolocic <br />consequence of mining. In order to provide the Division with adequate data upon <br />which it must write findings, Grand .Mesa Coal Company should: <br />1) Detcr.Tine the acuifer characteristics (i.e. trans:ressiv,ty (T) and storativity <br />(S)) for the E and D coal seams, the overlujno effected stratum, and the <br />"Glacial-Alluvial Aquifer". :his data is needed to deterr.,:ne the effects of <br />m_`ning on groundwater movement, on around and surface water depletion and on <br />crcundwater pollution movement. pp. 20,25,29 <br />1) Install more Groundwater ..^onitori no wet-'s in the "Glacia]-Alluvial Aouirer". <br />These wells should be spaced such that a detailed piezometric map can be prepared, <br />and the effects of undermining the "Glacial-A17uvi al Acuifer" can be assessed. Mdp 2 <br />This information is needed to deterr..ine the recharge and discharce characteristics <br />o_' this aouifer and the effect of mining on this aquifer recharge and discharge.. <br />3) Collect an adequate groundwater baseline. The permit application does not <br />contain a year's worth of groundwater level and quantity data, and therefore, Appendix <br />seasonal fluctuations in the quality and quantity of groundwater was not adequately E <br />addressed, and there is insufficient baseline data to compare with future ground- <br />water in order to determine the effects of mining on groundwater. The list of <br />water quality parameters which the applicant should monitor quarterly for both p' 74 <br />surface and groundwater samples is contained in Attachment A. This guideline <br />should be followed unless the applicant can demonstrate that such parameters are <br />not relevant. After a years baseline has been submitted and a complete analusis <br />of the roof, floor, interburden and coal for the E and D seams has beer. submitted, <br />the Division can reduce the number of parameter analyzed for, the number of sampling <br />locations and the frequency of sampling. <br />4) Conduct a spring survey. The application does not contain a spring survey. p 35 <br />A spring survey should be conducted to determine the discharge areas and dis- Mdp 2 <br />charging flows of aquifers in the permit and adjacent areas and to determine the <br />effects of mining on surface water flows through the depletion of spring flows. <br />This spring survey should include the location of all springs'in the permit and <br />adjacent areas on a hydrologic map; quarterlu field measurements of spring flows, <br />pX, temperature, and electro-conductivity; and information on water rights <br />associated with these springs. <br />11 <br />