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- 2 - <br />August 27, 1992 <br />2. NPDES outfall 011 is a ne~.a source. Therefore, the CDH required <br />that the operator monitor, in addition to other parameters, 011 for iS5 and <br />Total Iron weekly. Additionally, the operater must have at least 12 sample <br />results before requesting a reduciton in monitoring frequency. Because <br />discharge began during 1992 at 011, the Division may want to verify that the <br />prescribed monitoring plan has thus far been followed. See tables VI-4 and <br />permit for complete NPDES monitoring requirements. <br />Water Oualitv. Flow or Level Predictio <br />The operator contends that neither the inactive Somerset Mine nor the recently <br />activated Sanborn Creek Mine will significantly degrade the quality or <br />quantity of ground or surface water. <br />The operator maintains that the primary impact, if any, on NFGR will be on its <br />total dissolved solids (TDS) concentration. Based on historical data and low <br />flow conditions, the operator predicts TDS levels in NFGR to rise from a <br />baseline level 151 mg/1 (TDS avg. 1981) to around 300 mg/1 when water from <br />both the Somerset Creek Mine discharge to NFGR. <br />Historical date and monitoring during 1991 concurs with the operator's <br />predicted TDS levels. <br />The above prediction was based on conditions without inflow from the Rawlins <br />Sandstone aquifer to the "B" coal seam in the Sanborn Creek Mine. The <br />operator committed to a mine inflow study of the "B" Coal seam by the end of <br />1992. <br />The following comments pertain to Predictions <br />1. The 1991 AHR revealed flow in all drainages to reflect seasonal <br />variations and were not adversely impacted by mining activities. <br />2. Ground water levels in Somerset wells 6-6 and H-10 did not stablize <br />in 1991. <br />3. Should water levels in the Somerset mine workings exceed an unknown <br />threshold level, portal discharges may occur.Such an event would add creedance <br />to establishing a monitoring site downstream of the Somerset permit boundary <br />on NFGR as outlined previously. <br />4. The operator completed an inflow study of the "C" coal seam in <br />March of 1992 revealing inflow of 17 gmp and low TDS le•ie1; (300 mg;l). <br />5. The inflow study of the "B" coal seam yet to be completed may <br />necessitate a revision of predicted NFGR TDS level;. 8.5 feet of shale <br />separates Rawlins Sandstone Aquifer which exhibits TDS levels in excess of <br />7000 mg/1 (See SC-1 and SC-2 datea in 1991 AHR) from the "B" coal seam. Shale <br />is normally as excellent aquiclude but shculd inflow emanating from faults and <br />fractures in the Shale Stratum prove significant and requiie the ooerator to <br />discharge such water into sediment ponds and eventually PIFGR tds 1?eels may <br />