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January 14, 2004 <br />Page 3 of 4 Pages <br />due to the minor percentage of watershed azea involved." (Permit, page 4-110) No impact to the <br />surface water hydrologic balance of the Middle Thompson Creek drainage was anticipated (Permit, <br />page 4-114). Monitoring through 1985 did not establish depletion to the North Thompson Creek and <br />Middle Thompson Creek, and monitoring was discontinued in 1986 (Permit, page 5-I 15b). <br />It is possible that present and future mining activities may slightly reduce the flow of ground water <br />moving through the coals towards the Piceance Basin (permit, page 3-49). There is no monitoring <br />associated with groundwater flows to the Piceance Basin. <br />No adverse impact is inferred to regional groundwater, but not distinctly stated (permit, page 3-60). <br />There is no monitoring of regional groundwater flows. <br />A soil loss comparison, pages 4-19i through4-19iii of the permit, concludes that untreated drainage <br />(surface) from reclaimed areas would contribute slightly fewer suspended solids that untreated <br />drainage from the natural surrounding azeas. There is no monitoring associated with this conclusion. <br />A statement is made that water quality will not be impacted by suspended solids during reclamation <br />or after a lazge precipitation event (permit, page 4-105). "No dischazge" reports (Refuse and Pond 9 <br />sedimentation ponds) indicate performance within this prediction. An analysis after a vegetation <br />survey performed during July 1992 demonstrated that untreated drainage from the reclaimed mine <br />site does not contribute additional suspended solids above natural conditions. No monitoring is <br />accomplished for small areas that have exemptions from sediment pond treatments. <br />Seals (portals) were designed to withstand anticipated hydrostatic heads of flooded mines (permit, <br />page 4-66). However, the seals at Portal 1 did not prevent seepage of mine water, and drainpipes at <br />Porta13 allow for drainage of mine water. <br />"The refuse pile would have a minimal impact on the water quality of North Thompson Creek." <br />(permit, page 4-114) Surface runoff is directed into the Refuse Pile Sedimentation Pond, discussed <br />earlier. Data obtained for monitor well (refuse pile piezometer, directly below the pile) D-lA <br />indicates conductivities nearly double those of piezometer D-2A (located to the west of the pile). <br />Impacts on North Thompson Creek, however, are difficult to evaluate. No groundwater flow <br />information of the Refuse Pile is available. North Thompson Creek experiences rise in total <br />dissolved solids across the site (described as primazily from leaching of geologic formations <br />undisturbed by mining operations formations and treated mine water discharges in the PAP). The <br />AHR refers to baseline monitoring data and the discharges from Porta12 (Abandoned Mined Lands <br />peat bog water treatment system) for explanation for the increases. <br />"Surface entries and other accesses to the underground workings are located so that no gravity <br />discharge of water from the mines occurs." (permit, page 4-115). Seals were designed for lower <br />elevations projected to be below stable water levels subsequent to mine filling (permit, page 4-66). <br />Seeps were noted from the Mine 1 portals on Apri128, 1988 (seeps were actually reported in 1985 by <br />a Department of Health, Environment and Safety inspector in the vicinity ofthe air return). Grouting <br />