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n /~ XBOW MINING, LLC 3737 Hwy 133 P.O. Box 535 Somerset, Colorado 81434 USA Tel (970)929-5122 Fax (970)929-5177 September 20, 2004 Mr. Joseph J. Dudash Environmental Protection Specialist Colorado Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver CO. 80203 Re: Oxbow Mining LLC. Permit No. C-1981-022 Dear Mr. Dudash: RECEIVEp SEP 21 2Qpy Division of Minerals and Geology The purpose of this letter is to respond to the subject CDMG adequacy review for TR-47. The comments provided today also reflect OMLLC's understanding of the issues and discussions after our meeting with the Division on September 15, 2004. In attendance at the meeting were the undersigned representing OMLLC and Sandy Brown, Jim Burnell and Joe Dudash representing the Division. We thank the Division for the opportunity to discuss the issues before providing these responses. The following responses are presented in the order presented by the Division. 1. OMLLC's primary intention is to continue to recycle sump water back into the operation for such activities as dust control and motor cooling, etc. OMLLC desires to maintain future flexibility with respect to how it will handle sump water. While we may only need to presently pump the water one time, we want to maintain flexibility for the future. As we discussed during our meeting, data obtained from OMLLC's ongoing groundwater monitoring programs suggest that water found in local shallow alluvial groundwater, B-seam and the Rollins sandstone may contain moderately high levels of dissolved iron. Although the original source of water collected in the sump is from OMLLC's water rights along the North Fork of the Gunnison River and not groundwater inflow, there is some possibility that collected sump water could contain higher levels of dissolved iron. Such levels could be problematic with respect to NPDES discharge requirements. The flexibility to transfer water to the C seam workings aids in overall mine water handling. 2. As we discussed during the meeting, the MSHA letter was meant to represent a highly hypothetical situation related to miner safety. Discussions with MSHA involved an analysis regarding the improbability of transferred water from the C seam workings entering into the active D seam workings. While we noted in the MSHA letter the worst case scenario elevation of water in the abandoned C seam workings as being at the C seam Portal elevation, this discussion was only theoretical. OMLLC does not anticipate that transferred water will reach anywhere near the C seam portal.