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I?d Ral:cr <br />April K, 2002 <br />Page 2 <br />provide a rational basis for predicting potential Pancl 2 impacts to (I) the USDW aquifers <br />overlying the cavities, and (2) the Mahogany Zone. <br />Our expectation is that planned Panel 2 solution mining poses minimal risk for adversely <br />impacting the three overlying USDW aquifers. Longwall mining case histories suggest that <br />measurable changes in overburden hydraulic conductivity resulting lrom caving extend a limited <br />distance above the mining horizon. Any significant influence to hydraulic conductivity from <br />Panel 2 solution mining is most likely to attenuate within the R-6 aquitard, which isolates the <br />lower most USDW aquifer (B Groove) from the solution mining horizon. In the unlikely event <br />that communication channels open in response to mining, balanced pumping practices in the <br />cavities prevent the possibility of solution mining fluids migrating upward and mixing with the <br />USDW aquifers. Any flow would be expected downward as controlled by the natural hydraulic <br />gradient. The volume of tlow, if any, would depend upon the increase in rock mass conductivity, <br />the magnitude of the natural hydraulic gradient, and regional groundwater flow. I-Iowever, <br />longwall experience shows that caving-induced channels tend to close with time due to <br />compaction of the overburden, supporting our expectation that any induced flow would be <br />transient, rather than permanent. <br />We believe that Panel 2 plans pose minimal risk to the fitture mineability of the <br />Mahogany Zone. "fhe potential oil shale mining horizon lies in what is anticipated to be the <br />continuous deformation zone produced by very high extraction mining. While hydraulic impacts <br />' are expected to be insignificant due to attenuated connectivity between fractures and bed <br />separations, these same features pose some potential for ground control diftculties during future <br />oil shale mining. Possible problems could include pillar weakness, rib sloughing, roof falls, floor <br />' heave, offsets in the mining horizon, and generally less predictable conditions, similar to <br />conditions in the vicinity of faults or other naturally occurring disturbance zones. However, <br />these hazards are more likely to be infrequent, rather than ubiquitous over a cavity. Although <br />' some difficulties are possible as a consequence of Panel 2 solution mining, the impacts are not <br />likely to be pervasive enough or severe enough in nature to preclude successfultnining of tlrc <br />Mahogany Zone in the future. <br />' Background <br />Historically, similar concerns for the protection of overlying USDW aquifers and the <br />Mahogany oil shale mining zone existed at the planning stage for Panel 1 solution mining. <br />These were first investigated by Agapito Associates, Inc., (AAI) in 1988. The study concluded <br />' that 60-fr-wide pillars separating solution cavities would provide sufficient stability to minimize <br />the risk of disrupting the overlying aquifers and Mahogany 'Lone resource. Solution mining was <br />assumed to be confined to the Boies Bed. Conclusions were based on a review of lithologic data, <br />' overburden structure, regional iss situ stresses, calculated rock mass strength, the bulking <br />potential of caved strata, and numerical simulation of cavity roof stability. <br />t ~ J.F.T. Agapito & Associates, Ina (1988), "Caving Above Solution Cavities, IRI Leases, Piceance Creek Basin, <br />Colorado," Letter report by M. P. liardy to Mc Harold Raymond, RMF Mineral Swvices, hic., Job.No. 134-I, <br />' August 10. <br />' Agapito Associates, Inc. <br />