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<br /> <br />Mine, located on the other side <br />water. This is the same side of <br />a high a high sulfur content. <br /> <br />of Coal Gulch, does leak acid <br />the Gulch that the sample showed <br />3) Conversations with the Deluzio family, who mined the Victory <br />~3 .dine have shown that they never had a problem with sulfur in <br />any part of the seam or any localized area. <br />4) In the original Arness-Mc~riffin operation at the site, coal <br />and rock was removed from the surface area to make room for mine <br />facilities. According to the past operator, the initial coal <br />removed was high in 8TU but low in sulfur. But upon removing <br />additional material, the sulfur in the floor of the coal <br />increased in a very short distance. This also shows the localized <br />nature of the high sulfur area. <br />5) Localized high-sulfur areas such as this one are not uncommon <br />in the geologic record. Localization of high-sulfur contents may <br />be caused by isolated variations in the diagenetic history cf the <br />coal. However, in this case, it appears that the cause is <br />probably a local variation in the original depositional <br />environment of the coal. The floor material containing the high <br />sulfur content probably resulted from deposition in an isolated <br />pond or marsh that predated deposition of the main coal swamp. <br />Correlation of the geophysical ioc responses in the well control <br />near the high sulfur area tend to support this interpretation. <br />6) Although the data does not indicate that any high sulfur areas <br />will be encountered in the permit area, if any are encountered, <br />the probability is high that they will be localized. Also, steps <br />can be taken by the operator to ensure that no damage to the <br />hydrologic balance occurs. Water inflow was never a problem in <br />any of the old mires of the area and no water was ever pumped <br />`rpm any of the Victory ,dines. The groundwater report in the <br />permit 3DD1lC3tiOn also indicates little water in any of the <br />three formations o` concern. If water is enccuntered underground <br />and does interact with a high pyrite area to produce acid water, <br />the water can be pumped to the surface and treated before leaving <br />the site. Pumping and treating acid water at mine sites is very <br />common in the eastern United States. <br />As stated in Cathy Begej's letter, the proposed mine is shallow, <br />with depths ranging from 0 to 500 feet o` cover. This is true and <br />rock mechanics at these depths indicate that ~,, is highly <br />unlikely that the strata o` the Point Lockout Sandstone would be <br />