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indicating that backfilled aeeas have become spoil aquifers in equilibrium with charge and dischazge cycles. As <br />revegetation of reclaimed becomes more and more representative ofpre-mining vegetative cover, and as reclaimed <br />surfaces are similar in topography to pre-mining conditions, surface runoff likely approaches pre-mining levels. The <br />difference at this time is that surface runoff is collected and directed to sedimentation ponds, with point discharges. <br />For most of the site, these point discharges are representative ofpre-mining drainage discharges, and the ponds have <br />been permitted as permanent features. As the ponds aze generally full, inflow is equivalent to dischazge. Any <br />infiltration of precipitation over and above pre-mining conditions is likely recovered in the spoil spring discharges. <br />Disturbed areas of the Oak Creek drainage have been, for the most part, reclaimed, and sedimentation ponds have <br />been removed. There is no post-mining condition that would deplete runoff from these areas from pre-mining <br />conditions. Flows in Oak Creek aze not monitored. <br />An impact to surface water quality was anticipated in Trout Creek. The amount was anticipated to vary significantly, <br />and is greatly dependent upon flows (seasonal and irrigation calls) in Trout Creek as variations in spoil spring flows <br />are more moderated. TDS values were expected to rise as high as 1,186 mg/1 at some time during the mining and <br />postmining era at the Edna Mine (PAP, page 2.SA-7). However, an annual average of 196 mg/1 is anticipated on <br />page 4.6-61(a} of the PAP. The operator is asked to review this section of the PAP. <br />Sulfate concentrations were expected to reach an upper limit of approximately 842 mg/1 (PAP page 2.SB-3) in Trout <br />Creek. Monitoring station TR-D is below mining activity on Trout Creek. TDS values reported For TR-D ranged <br />from 170 to 950 mg/1 during the 2004 water year. Sulfate concentration ranged from 110 to 590 mg/1 at this surface <br />water monitoring site. A summary statement that all values for TDS in Trout Creek are consistent with the probable <br />hydrologic consequences projections is made on page 9 of the AHR. This review validates this statement, and also <br />finds that sulfate concentrations were within the anticipated range. <br />An impact to alluvial groundwater of Trout Creek was anticipated. TDS in alluvial materials was expected to rise to <br />2000 - 3000 mg/1(PAP page 2.5-97). Alluvial groundwater is monitored at three stations, TR-1.5 above mining, TR- <br />3 at the northern limit of mining (downstream), and TR-4 approximately a mile below mining. TDS values in <br />alluvial monitoring well TR-1.5 ranged from 4210 to 4620 during the 2004 water year. High TDS values in TR-1.5 <br />have been noted for a number of years, and they continue to rise. There is only speculation (in the PAP) for high and <br />rising TDS values in TR-1.5. TDS values in TR-3 ranged from 430 to 860 mg/1, and in TR-4 from 460 to 960 mg/l. <br />Impacts to alluvial groundwater of Trout Creek are within those predicted. <br />No impact to alluvial groundwater in Oak Creek was anticipated (PAP page 2.5-95b), and no groundwater <br />monitoring was conducted. <br />No probable hydrologic consequence was predicted in the PAP for bedrock groundwater. Bedrock aquifers that abut <br />spoil backfill probably are too impermeable to transmit any significant amount of leachate. Those bedrock units in <br />close proximity to the floor of the pit aze exposed (or covered with a shallow mantle) below the pit and above Trout <br />Creek. However, a monitoring station (an existing, privately-owned well) was established in the Trout Creek <br />Sandstone (a unit some 150 feet or more below the pit floor) directly downdip of mining activity. Monitoring from <br />1995 indicates that TDS values have remained consistent in a range from 440 to 840 mg/1, with no appazent rising <br />trend. Monitoring at this station was not (due to equipment problems - no power) accomplished during the 2004 <br />water year (brought to the attention of the operator). <br />CWQCCR 31 <br />Basic standards and methodologies for surface water are defined in Colorado Water Quality Control Commission <br />(CWQCC) Regulation (CWQCCR) 31. Surface runoff and spoil leachate from mined areas at the Edna mine <br />Page 5 <br />