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Mr. Phil Schmidt <br />March 25, 1998 <br />Page 2 <br />provided by MCC's consultants, derived following the issuance of Notice of Violation CV-97-022, <br />were reviewed by DMG staff. These materials contain possible discrepancies or reflect inadequacies, <br />as discussed in more detail below. We wish to provide MCC the opportunity to address these <br />possible discrepancies. <br />Hvdroloeic Impact Monitorine <br />Information submitted to date does not appear to indicate adequate monitoring of potential hydrologic <br />impacts from the storage of water in the NW Panels sealed sump. Specifically, there do not appeaz to <br />be any functional groundwater monitoring locations in place to allow an assessment of the water <br />contained within the NW Panels sump, and any impacts associated with the storage of these waters. <br />However, the storage of approximately 385 acre-feet of water in the NW Panels sump may potentially <br />be causing a significant adverse impact down gradient. Therefore, effective monitoring must be <br />addressed. <br />1) .Does MCC have any means by which NW Panels sealed sump waters, and adjacent <br />groundwater resources can be directly sampled, other than at the Lone Pine discharge <br />location? If not, please provide a plan which will effectively monitor water in the NW Panels <br />sump and adjacent areas. <br />2) According to the MCC 1996 AHR, groundwater well LP-1 exhibits a water level increase of <br />approximately 40 feet from May or June 1995 in to May or June 1996. As a well completed <br />in the Rollins sandstone immediately below the B seam, this monitoring point may provide <br />pertinent information regarding impacts from the NW Panels sump. However, MCC now <br />seems to be encountering difficulty in obtaining measurements from this well as the MCC <br />December 11, 1996 AHR response indicates that well LP-1 is a "candidate for replacement". <br />Please expedite maintenance of this well to ensure proper function and indicate why you <br />believe that this well is not functioning properly? <br />3) Are any of the drill holes SOM 11, 12, l4, 17, 33, 34, 36, 4l, C70, and 120 open and in a <br />condition to allow effective groundwater monitoring? <br />Bear Mine Inflows Prior to November 1996 <br />There are apparent inconsistencies within the various information sources relating to Bear mine <br />inflows. The inflows observed at the Beaz No. 3 Mine, 3rd west section, during 1995 and 1996 <br />correlate precisely, both in time and space, with the use and sealing of underground sumps within l <br />NW - 5 NW Panels at the West Elk Mine. Available maps indicate that the B Seam coal barrier <br />between the West Elk and Bear Mines may be as narrow as 200 feet in this area. Various MCC <br />writ[en documents indicate the use of sumps in the l NW - 5 NW Panels, adjacen[ to the location of <br />the inflow observed within the Bear Mine at the 3rd west section. Observations by BCC personnel of <br />water flowing from the coal rib in this area seem to verify that, at this location, some amount of <br />