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133 <br /> 1 geophysical behavior, your knowledge of the area and 1 review of the report, what did it show, or how did <br /> 2 geology, and your observations and information 2 you interpret it? <br /> 3 provided to you by Snowcap, did you develop a 3 A. Based on my review of the report, the <br /> 4 working hypothesis for investigations at the site? 4 data was pretty clear that a vertical anomaly <br /> 5 A. I did. As indicated in May 9 report, 5 existed in the subsurface, and it happened that the <br /> 6 based on my observations of the soil conditions, the 6 vertical anomaly was in the general location of <br /> 7 information from the drilling contractor, general 7 where we suspected the old air shaft to be. <br /> 8 information of the geology in the area, and 8 Q. Okay. Could you describe any other <br /> 9 recognizing how significant of a sinkhole -- a 9 anomalies that the first survey showed or you were <br /> io pathway would have had to exist to get that much 10 aware of? <br /> 11 water into the mine that quickly, I felt it unlikely 11 A. well, the first survey primarily -- <br /> 12 that a natural —what we could call a natural I12 again, with the electrode spacing, our intent was to <br /> 13 sinkhole was the cause of that hydrologic 13 cover a large area, including the Carey Pond area, <br /> 14 communication. 14 to see if we could establish a communication link <br /> 15 I felt it much more likely -- and at 15 between the surface and the mine. <br /> 16 this time I was unaware of the existence -- or at 16 And although there was some minor <br /> 17 least initially I was unaware of the existence of I17 anomalies here and there, the primary anomaly was <br /> 18 the air shaft, but I hypothesized that there had to 18 the vertical anomaly identified in the report, and <br /> 19 be some sort of man-made feature, either an air 19 that is why we later asked Rigro to cane back and do <br /> 20 shaft or an old borehole or something, that was a 20 an additional survey with a tighter electrode <br /> 21 vertical pathway to get that much water into the 21 spacing in order to increase the resolution in the <br /> 22 mine. 22 near surface. <br /> 23 Q. Okay. what did you do to follow up 23 We knew that we had a hole here <br /> 24 on the hypothesis? 24 (indicated), and we knew that the vertical air shaft <br /> 25 A. In contact with Snowcap and J.E. 25 showed up in the initial survey pretty clearly, but <br /> 133 135 <br /> 1 Stover, I became aware that there was, in fact, a 1 we -- after the initial survey, we weren't able to <br /> 2 air shift in reasonable proximity to the sinkhole 2 definitively connect the two. <br /> 3 opening at the end of the Fontanari Ditch, and that 3 Q. Okay. But with respect to the Carey <br /> 4 is when I contacted Mr. Hiild with Fugro to develop a 4 Pond, what was the conclusion? <br /> 5 geophysical exploration plan. 5 A. Well, the data did not show any <br /> 6 Q. And the survey they recommended 6 pathways leading from the Carey Pond. <br /> 7 was? 7 Q. So why was the second Fugro analysis <br /> 8 A. He recommended doing an electro -- 8 taken? <br /> 9 electrical resistivity tomography. 9 A. As indicated before, we knew where <br /> 10 Q. Okay. 10 the water was entering at the ground surface, and we <br /> 11 A. Sorry. 11 were -- had a reasonable degree of confidence of <br /> 12 Q. And we've already gone over 12 where -- how it was getting into the mine, but we <br /> 13 Mr. Hild's testimony. But how many ERT surveys did 13 weren't sure of the path that it took from the <br /> 14 Fugro conduct? 14 surface opening to the air shaft, and specifically <br /> 15 A. Two. 15 we weren't clear at what depth. <br /> 16 Q. Okay. And were those at your 16 In order to develop a mitigation <br /> 17 instruction — at your request? 17 plan, we had to make sure that wherever we installed <br /> 18 A. Yes. 18 a plug to seal the air shaft was below the point at <br /> 19 Q. All right. The first evaluation, is 19 which the -- the point of connection between the <br /> 20 that the report previously admitted as Exhibit 29? 20 surface hole and the air shaft. <br /> 21 MR. BECMTH: I will stipulate that 21 Q. Okay. <br /> 22 it is, Your Honor. 22 A. So we asked them to conduct an <br /> 23 A. Yes. 23 additional survey. <br /> 24 MR. SIN=ARY: Thank you for that. 24 Q. And what were you able to determine <br /> 25 Q. (BY MR. JUSTUS) Okay. Based on your 25 from that additional data? <br /> 134 I 136 <br />