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We estimate the east C seam workings have a total water holding capacity in excess of 600 <br />million gallons of water. When added to the west C seam workings plus the underlying B seam <br />workings, available water holding capacity would certainly exceed 1 billion gallons of water. As <br />noted in our TR-47 application, the effect of 3 million gallons of water transferred to C seam <br />would be inconsequential and would be predicted to quickly dissipate throughout the old mine <br />workings. There are no circumstance in which we believe that transferred water into the C <br />seam workings would ever be expressed at the surface near the C seam portals. <br />2A. Please see the attached revised PAP page 2.05-96a and 96b discussing the probable <br />hydrologic consequences of the proposed transfer of water to C seam. There are no <br />connections between the old C-seam workings and the Sanborn Creek mine workings, The two <br />workings are separated by considerable distance of coal barrier pillars and the migration of <br />transferred water into the Sanborn Creek Mine is considered highly unlikely. <br />2B. As discussed in the meeting, OMLLC expects there will be no discharge of water from <br />the C seam portals and, as such, transferced water will never reach the North Fork of the <br />Gunnison River. We do, however, have an analysis of two May 21, 2004 sump water samples. <br />The analyses are attached for the Division's information. To insure the water is operationally <br />suitable for re-use in the mine, the sump water is drawn from the bottom of the sump and routed <br />through a mechanical filter to remove any suspended solids above 25 microns in size. The <br />attached analysis for "pre-filter" and "filtered" demonstrates the effectiveness of the filter to <br />provide water that meets not only the operational requirements but applicable pH and TSS <br />requirements. <br />2C Please find attached Map 2.04-M46, sheets 1 and 2, "C" Seam Isopach showing the <br />connecting features between the C seam workings and the B seam workings. The map shows <br />the rock tunnel raises, ventilation boreholes, other boreholes, etc. The current and approved B <br />seam monitoring program will remain unchanged. The H-10 borehole will monitor for B-seam <br />water levels (currently the mine is dry). The B-6 well is scheduled to be abandoned and <br />plugged with concrete as part of D seam development. OMLLC will monitor the C seam <br />borehole for water levels at the same frequency currently in place for the H-70 well and report <br />the results in the Annual Hydrology Report (AHR). Please see the attached revised pages 2.05- <br />96b, 2.05-00, Exhibit 2.05-E7, Page 1 for details of the revised monitoring program. <br />2D. We anticipate transferring up to 3 million gallons per year. Pumping records will be kept <br />and the annual volume of water transferred will be noted in the AHR. <br />2E. Please see the revised Permit Page 2.05-96b for a discussion of the volume available in <br />the abandoned B and C seam workings. We have no information suggesting that hydraulic <br />seals or bulkheads were installed in the C seam workings. Interviews with local miners with C <br />seam experience suggests the C seam mine was dry and such seals would not have been <br />used. <br />3. OMLLC owns or purchases additional water rights intended to be fully utilized and <br />"consumed" by the mining operations (with a portion used by the town of Somerset). Unlike <br />agricultural water rights where there may be an expectation of return flows from irrigation activities, <br />there is no requirement or expectation for any return flows to the North Fork of the Gunnison River. <br />4. Map 2.05-M1 -General Facilities has been modified to include the injection well within <br />the disturbance boundary and present disturbed area. No new additional acres of disturbance <br />are required. <br />