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above probably means that the waters aze not of the same origin. Again, without <br />additional testing, it may be impossible to tell. <br />Second, it is not possible to say that the water is any kind of natural groundwater with the <br />data provided. The fact that similaz water appeared in well AA-1 is not indicative that <br />the water is groundwater. What is more likely is that the water from the spring began to <br />seep and infiltrated the alluvium and contaminated the alluvial well water. This is <br />consistent with the events that lead up to the slide of the portal area followed by the <br />spring water coming out where it currently does. <br />Third, the letter from Beaz Coal dated 9 May 2000 states that Bear never used the <br />Edwazds Mine portals for their operations. This, however, is uncleaz in the permit. Page <br />2.05-Sb states that "(u)tilizing the portals of the abandoned Edwards Mine has increased <br />recovery of the reserves and caused minimal additional surface disturbance." Page 2.05- <br />6 states "(a)ccess to the B-Seam was accomplished by the use of two rock slopes and a <br />ventilation opening developed from the C-Seam to the B-Seam..." These two <br />statements, which appear to be contradictory, do not help the situation. If Beaz did not <br />use the Edwards Portals at the B-Seam and did not mine into or through the Edwards <br />Mine's workings, it may be easier to prove that water coming out of the Edwazds Portals <br />is not from the Beaz Mine. <br />Fourth, based on text and tables in the AHRs that were reviewed, there were no mine <br />inflows until 1995 (approximately 18 gpm or 6 million gallons). The inflows continued <br />and increased in 1996 to approximately 40 gpm (or 15 million gallons). The inflows <br />were coming from sealed azeas ofthe mine that were dry during mining (as evidenced by <br />no inflows being reported prior to 1995). Bear maintains that the water is coming from <br />the West Elk Mine. I have not reseazched when West Elk began Bumping water in the <br />azea. <br />The conclusion of my reseazch is that, given the information currently in the Division's <br />possession, there is no way to definitively determine the source or origin of the water. If <br />I had to make an educated guess, I would say that the water is not the same water that <br />was flowing into the mine in 1995 and 1996. The water in well AA-1 appazently <br />"changed" and "became" the brownish water that is now discharging from the portal <br />spring sometime in 1989. If this were the case, it would point to the fact that they are not <br />the same waters. A point that bears mentioning (no pun intended) is that the water <br />discharging from the Edwazds Portal spring is basically benign. It meets all applicable <br />stream standazds and has no organic constituents of concern (it is still my opinion that the <br />brownish color is coming from humic acid, a beneficial organic acid). Both upstream and <br />downstream samples show no effects from the dischazge of the spring water into the <br />North Fork of the Gunnison River. Another interesting issue is that a very similaz water <br />appears at the Bowie No. 2 Mine, which is located across the river, approximately 1 mile <br />west and several hundred feet higher in elevation. <br />There are several items that Beaz could do if they wanted to invest a few thousand dollazs <br />and maybe come up with a firmer conclusion. Beaz could sample both the Edwazds <br />