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Mr. Greg Lewicki Page 2 <br />Greg Lcwicki and Associates <br />June 24, 1997 <br />values in 1996 (see attached table). These data are within the historical <br />ranges for this sampling location. Prior to 1995, samples for the alluvial <br />station were taken from a 17-foot deep well located 30 ft. from Trout Creek ~ <br />and therefore are not exactly comparable to subsequent alluvial station ~., rer,U ~ <br />samples that have been taken directly from the creek. Upstream sampling P ~ (~ ~ <br />frequency in 1996 fell one sample short of the triennial regimen specified in! 3I I t'9 <br />the permit application. The Division requests an explanation of the a ~ gIZfS~ <br />omission. <br />Sample data from the downstream surface and ground water monitoring <br />sites also were within their historical ranges, but are not considered to be <br />reliable enough to warrant discussion because of possible confounding by <br />water inflows from other mines (see Item 4 below). <br />The probable hydrologic consequences section of the permit application <br />focused mainly on impacts to Middle Creek, a perennial stream that lies on <br />the other side of a ridge from the Apex No. 2, one mile northwest of the <br />mine's surface disturbance. Middle Creek is geologically downdip from <br />underground workings of the Apex No. 2. It is unlikely that the Apex No. 2 <br />underground workings contribute any appreciable quantities of ground <br />water to Middle Creek or to the subsurface beneath Middle Creek. The <br />mine's portals are now sealed. The mine's location at the updip outcrop of <br />the now mined out coal beds precludes any regional flow of groundwater <br />through the underground workings, and the semi-arid climate precludes the <br />infiltration of any precipitation through the overburden down to the <br />underground workings. <br />(~le~} .a i,~ <br />I~~~~~ <br />~~fi~ <br />y~,- <br />M~ <br />I~~is <br />P~R~ <br />Virtually all surface runoff currently flowing from the Apex No. 2 surface <br />disturbed area flows into the Trout Creek drainage. Most of the runoff from <br />the surface disturbance is routed through a sediment pond in the former <br />facilities yard. This pond has not discharged for at least 3 years. A fair <br />amount of runoff flows off of the permit area at times from the small area <br />exemption located in the former office area. <br />Perhaps the greatest potential source for ground or surface water <br />contamination from the Apex No. 2 disturbed area is the 3-acre reclaimed <br />facilities yard area next to Trout Creek. The 6 inches of topsoil on this <br />regraded and revegetated area covers a layer as much as 5 feet thick of <br />