2019-10-22_REVISION - C1981041 - Laserfiche WebLink

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JAMES A.BECKWITH FONTANARI OBJECTIONS AND COMMENTS I SNOWCAP BOND APPLICATION SL-1 I I PG. 15 This resulted in Powderhorn reporting a ``spike" of mine inflow water from Meter Locations 3 and 17. (In those years, Powderhorn had in-mine meters gauging the amount of inflow at as many as 35 different locations). The "spike"was only 30 GPM over a three-week period. (See: Exhibit 11) When the mine and portals were sealed in 2000 these in-mine meters were rendered useless and inaccessible. Thus, Snowcap's 3 cfs rate is based on "eye-balling" and not actual calibration or measurement. These inflows were metered at 30 GPM net. Examination of Snowcap's 2014 Annual Hydrology Report reveals that none of its actual metering (Monitoring Well N-1; Outflow 01 b; Seepage at the Dirt Plug; French Drain outflow) result in matching inflow/discharge rates, and none of these meter readings support the claim of 3 cfs. Fourth, the Annual Hydrological Reports for the period 1987-2000 do not support Snowcap's claim that water volumes flowing into the mine equal the water volumes flowing out of the mine. The Mine Dewatering System was designed and built in 1994, and modified in 1999 with the outflow 016 Drain. In the absence of inflow meters, DRMS cannot determine how much water is actually flowing into the Roadside Mine under well Permit 33210-F. More importantly, measurements at Outflow 016 discharge point in June 2018 revealed only 93 GPM being discharged into the Colorad❑ River. Snowcap's meter consistently read 275 GPM, but examination confirmed the meter had not been installed in accordance with manufacturer's specifications in other words, it is simply inaccurate. Notably, the Annual Hydrological Reports discloses that neither Powderhorn nor Snowcap reported any"accuracy tests" of its meters at any time. This begs the question as to whether, over the 24 years since construction of the Mine Dewatering System, tunnel collapses and natural wear and tear have altered the system's efficiency. whether water is being impeded (though not impounded) within the Roadside Mine is unknown absent further inspection and report. That knowledge is crucial to determining whether or not Snowcap as complied with its remediation and repair obligations and its Application should be granted. IV. CONCLUSION Snowcap's request for a bond release relies on the assumption that there has not been active subsidence since the June 1991 survey by Mr. Magers. This assumption fails as to Tracts Nos. 70, 71 or any other tract. Snowcap ignores Mr. Magers' own report that, in June, 19911, the six stress cracks in Tract No. 70 were already one large stress crack 200 feet in length; 9 feet in depth; and 1-3 feet in width. Snowcap ignores the irrefutable physical evidence of Subsidence Events D, E, F and G: which have emerged since 2016. Snowcap ignores the in-line sinkholes at Event F, lying directly over identified coal tunnel collapses. Snowcap's Application should not be granted based on this willful ignorance.