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Probable Hydrologic Consequences New Elk Mine 28 <br />increase the currently observed drawdown in the Allen and Apache Coal seams. Water level data from <br />packer testing indicate that steep vertical gradients currently exist in the strata adjacent to coal seams. The <br />steep gradients are related to mine dewatering and /or CBM production and suggest that there is limited <br />potential for propagation of drawdown across bedding. No flow or water quality impacts are expected to <br />occur to surface water including springs and seeps due to mine dewatering. Approximately half of the <br />groundwater wells located within a one -mile radius of the permit boundary are completed in alluvium at <br />depths less than 66 feet. No impacts to water level or water quality are expected to occur in alluvial wells. <br />Well records from CDWR indicate that there are 19 permitted wells in the Raton Formation within a one <br />mile radius of the permit boundary. The wells vary in depth from 30 to 750 feet, and have completion <br />water levels ranging from 5 to 598 feet bgs. A study by Watts (2006b) evaluated the potential for <br />groundwater pumping from coal seams in Las Animas county to impact water levels in wells that are used <br />for water supply. He noted that because the permeability of stratified sedimentary rocks generally is <br />greater parallel to bedding than across bedding, the drawdown of water levels in coal seams would have the <br />greatest potential for interfering with nearby water - supply wells in areas where there is little vertical <br />separation between the coal seam and the well production intervals. The analysis assumed that a vertical <br />separation of 100 feet between coal seam and water supply wells would be protective of water supplies, but <br />it was careful to note that the required separation would depend on local geologic conditions. Mining <br />related subsidence will increase vertical permeability for up to 195 feet above the highest mined coal. <br />Wells that produce from 100 feet or higher above the zone of increased vertical permeability are not likely <br />to be adversely impacted by mining. <br />Two bedrock wells are located near the planned mining area in the Allen Seam. The wells are in the <br />northeast half of Section 24, T33E, R68W. Well number 284213 is a monitoring well owned by NECC and <br />is completed in the Allen Seam. The well is 442 feet deep and is designated as NE -1 -10 for the monitoring <br />program. The other bedrock well (permit number 264440) is 200 feet deep and is completed in an <br />unidentified coal bed. The owner of record for the well is Helen Armstrong. Four shallow alluvial wells <br />(12, 13, 14 and PAW -9 on Map 8) are also are also located in northeast half of Section 24, T33E, R68W. <br />Wells 12, 13, and 14 are on land owned by J.I. Vialpando. Well PAW -9 is a monitoring well owned by <br />NECC. Mining of the Allen Seam may have the potential to reduce water levels and impact water quality in <br />the Armstrong well. In the event that water in the well is impacted by mining, the water supply will be <br />replaced with water from the city of Trinidad (city water). Well NE -1 -10 is designed to monitor potential <br />impacts to groundwater in the mining horizon, and impacts to water levels or water quality in the well are <br />not an issue with respect to water supply. Wells 12, 13, 14 and PAW -9 are situated more than 400 feet <br />above the planned mining horizon, and impacts to water quality and availability are not anticipated to these <br />wells. In the event that unanticipated impacts occur the water supply will be replaced with city water. <br />Dewatering discharge from the mine will be treated before being released to the Purgatoire River, and <br />impacts to water quality in the river from discharged water are expected to be similar to those currently <br />observed (i.e an average increase of about 40 mg /1 TDS downstream from the mine). Water quality in the <br />mined coal seams in the permit area is expected to be impacted by the mining operation. Impacts to water <br />quality will include an increase in TDS, mainly in the form of sodium and bicarbonate. Background TDS <br />concentrations in the Allen and Apache coal seams are estimated to be about 435 mgl/L and 1,105 mg/L <br />respectively based on the electrical conductivity (EC) of groundwater from monitoring wells NE -1 -10 (623 <br />µS /cm – Allen) and NE -6 -10 (1,106 µS /cm – Apache) and the assumption that TDS is equal to about 70% <br />of EC. Observed TDS in the sealed portion of the New Elk Mine has averaged 1,628 mg/L. After mining, <br />the TDS concentration of groundwater in the Apache and Allen coal seams near the underground workings <br />is expected to be similar to water in the sealed mine. <br />Monitoring of impacts during mining and previous studies of probable hydrologic consequences (WWL, <br />1980 and Greystone, 1994) indicate that underground inflows and mine dewatering have little or no <br />communication with surface water. This conclusion is consistent with the subsidence analysis and <br />4164A.110421 Whetstone Associates <br />Iry cA QtAn 13— 1 no n MAI i <br />