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Dan Hernandez Page 13 <br />June 3, 2013 <br />Groundwater monitoring has been limited to the coal seams and underground workings given the <br />very low probability of any impact to the underlying Trinidad Sandstone or the overlying <br />colluvial /alluvial deposits. Additional monitoring in the isolated saturated zones that may exist <br />in the Vermejo Formation above the Red Arrow and Jack O'Lantern coal was not implemented <br />because these perched zones are laterally discontinuous and have very low hydraulic <br />conductivity. Establishing a network of monitoring wells above the coal seams mined was <br />deemed impractical particularly since exploration drilling within the mine area did not <br />encountered any significant aquifers or other groundwater resources. Given the extensive past <br />surface and underground coal mining in the study area, groundwater impacts (both magnitude <br />and extent) are difficult to predict. Results from the current monitoring program show that there <br />has been little change in water quality within the coal seams and flooded mine workings of the <br />Southfield Mine. AHRs have indicated that in general the water quality in the monitoring wells <br />at the mine site has not significantly degraded over time. Groundwater within the coal seams <br />and workings was likely compromised by historical mining prior to the current mining operation. <br />Groundwater in the flooded mine workings, as well as water in coal or low permeability rock <br />interbedded with coal down gradient of the flooded mine workings, does not need to meet water <br />quality standards as indicated in the citizens complaint presented by the Vento family. As <br />previously described and stated in Regulation No. 41, "Mining activities are recognized to occur <br />within ground water bodies and that water quality within the disturbed area will obviously <br />change." Further, and of major importance here is the fact that the Colorado Division of Water <br />Resources recognizes that groundwater obtained from coal zones is known to be of degraded <br />quality and advises against completing wells for domestic or agricultural purposes in these zones. <br />I don't find any indication that wells within or adjacent to the permit area have been impacted by <br />the current mining operation. There are three privately owned wells completed above the <br />Southfield workings within and adjacent to the permit area as described previously. The Corley <br />Company Well and the Thompson Well are both permitted by the Division of Water Resources. <br />If the present landowners wish to install wells on the property for domestic or agricultural <br />purposes then these should be located outside of the coal zones. Since existing groundwater <br />quality within the coal seams and underground workings is known to be of degraded quality and <br />likely also reflects the effects of previous coal mining activities, the Trinidad Sandstone or the <br />shallow colluvial /alluvial deposits would be a better source for groundwater to be put to <br />beneficial use. These geologic units have been unaffected by the mining. <br />The mining operation has ceased and the workings have been properly sealed. There should be <br />no reason to expect further disturbance at the site or further degradation of water quality within <br />the Red Arrow /Jack O'Lantern coal seams or workings. MW -65 is operational and serves as the <br />current down gradient monitoring well completed in the Jack O'Lantern coal seam. MW -65 is <br />completed to a depth of 988 feet below ground surface. Additional monitoring of the coal zone <br />is not warranted. Given the surface topography and geologic structure, to install additional wells <br />down gradient of the mining activity one would have to go higher in elevation and drill a deeper <br />well targeting the coal seam(s). Since groundwater in the coal seams is already known to be of <br />degraded quality and unlikely that it would be put to beneficial use, this would provide little <br />additional information and be both technically and economically challenging. Given the above <br />