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JAMES A.BECKWITH FONTANARI OBJECTIONS AND COMMENTS/SNOWCAP BOND APPLICATION SL--1 1 /PG. 14 Unfortunately, Snowcap's Annual Hydrologic Reports and its claims in Tab 9, Application, are unreliable and cannot serve as a basis for bond release based upon water issues. First, Snowcap's Annual Hydrologic Reports have correctly admitted that no "beneficial uses" of the mine water have occurred (i.e., coal-washing; dust control; fire suppression) because mining ceased in 1999 and the Roadside Mine was sealed in 2000. Notably, however, since 2006 to the present date, Snowcap's Annual Hydrologic Reports have stated that"Consumptive use(of mine water) will be for seeding and dust control during reclamation operations." (Emphasis added) Snowcap has regularly reported the Sodium Adsorption Rate (SAR) at a concentration considerably greater than 9 PPM. Water containing an SAR of 9 PPM or granter is toxic to all living plants. (Fontanari Exhibit 26) Broadcasting the mine water on the Study Area's surface would have killed all vegetation installed under Snowcap's revegetation program. Since the revegetated areas are thriving, the conclusion is obvious: Snowcap has never used mine water to irrigate the vegetation. The August 14-16 inspection failed to reveal any mechanical means by which Snowcap pumped water from the mine, cleaned it to usable quality standards, and broadcast it on the revegetated areas by sprinkler or other means. Second, since 2001, Snowcap has regularly reported 275 +/- GPM as the volume of mine water discharged directly from the Roadside Mine into the Colorado River. Snowcap installed a meter at outflow 016, and replaced it with an identical meter in January, 2017, but failed to install either of the meters in accordance with the manufacturer's specifications. The result is that the meter readings are inaccurate and unreliable. Actual measurement of the discharge amount, in June, 2018, is 93 GPM, not the 275 GPM reported by Snowcap. Tontanari Exhibit 27) And notably, the Bond Release Inspection of August 14-16, did not include any collection of water quality samples nor measurement of the actual volumes of water discharged to the Colorado River. It is also true that neither Powderhorn nor Snowcap ever reported, in their Annual Hydrologic Reports, any backup tests to verify the accuracy or calibration of the meters and gauges upon which their disclosed data to DRMS was based. Third, pre-Snowcap Annual Hydrologic Reports contradict, if not refute, Snowcap's assertion that in June, 2014, 3 cfs (22.4 gallons/sec or 1,346 GPM) of irrigation water flowed from the surface of Tract No. 71 into the South Portal of the Roadside Mine. In 19921, 1993, and 19945 surface irrigation water was applied to Tract No. 71 by Rudy Fontanari, then land manager for Powder Mountain Ranch, the tract owner. The water source (Martin Crawford Ditch; Rapid Creek), the water volume, and the period of irrigation were identical to the source, volume and irrigating time in June, 2014. The sole difference was that water was put into Carey Pond.