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indicated excessive clay content. Such high clay areas are ripped during regrading <br />operations to relieve compaction. No indication of the presence of acid forming or <br />otherwise deleterious regraded spoil has been found by the Division during mine <br />inspections. <br />Based on the baseline data and assessment provided in the permit application, <br />monitoring commitments described for both the Wadge and Wolf Creek/Sage Creek <br />spoils, and monitoring results and observations to date, the operation is in compliance <br />with performance standards related to acid forming and toxic forming spoil. <br />E. Surface and Ground Water Monitoring <br />Ground Water <br />Tab 7 of the permit application contains baseline ground water hydrology information. <br />Section 7.1 contains the baseline information for the original permit area, while <br />Section 7.2 contains updated information for the Seneca H-W South Extension Area. <br />The ground water information section of the application was most recently updated in <br />2002 in association with Permit Revision No. 3 (PR-3). Tab 15 describes the <br />operational ground water monitoring program. The current hydrologic monitoring <br />program is presented in Appendix 15-3a of the permit application package, updated in <br />association with TR-63 in 2009 and TR-69 in 2010. Monitoring locations are shown <br />on Exhibits 7-1 (for the original permit area) and 7- lA (for the South Extension Area). <br />Ground water studies in conjunction with the Seneca H-W Mine site have been <br />concentrated in the Upper Mesaverde Group and alluvial aquifers. Specifically, <br />aquifer characteristics and/or water quality analyses have been performed in the Wolf <br />Creek underburden, Wolf Creek coal, Wolf Creek overburden, Sage Creek coal, Sage <br />Creek overburden, Wolf Creek/Wadge Interburden, Wadge coal, Wadge coal <br />overburden, and the Hubberson Gulch alluvium. Quantity and quality data have also <br />been collected from ten springs and seeps in and adjacent to the permit area, and three <br />spoil springs that have developed on reclaimed areas. The current monitoring plan <br />requires monitoring of water quality and/or water levels at specified intervals at <br />thirteen bedrock wells, two alluvial wells, four natural springs and seeps and five spoil <br />springs. Each year following snowmelt, any additional spoil springs with discharge of <br />at least 5 gpm are documented, monitored in spring and fall, and reported in the <br />Annual Hydrologic Report for the year. <br />Each of the identified aquifer zones is hydraulically discontinuous with the units above <br />and below. Therefore, each aquifer will be discussed as a separate entity. <br />Seneca II-W Findings Document 28 01982057 <br />Permit Renewal No. 5 December 9, 2010