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10/06!2004 15:42 19709295177 <br />10/06/2004 14:23 303-231-5553 <br />OXBOW MINE <br />t•KHA <br />PAGE <br />04107 <br />PAGE 04/07 <br />The Daly other MSHA regulation that could apply would be 30 CFR 75.1716. This coacean has been <br />previously addressed in a letter to your office dated January 10, 2003. To recap, the Elk GYeek Mine is <br />currently developing m the D-Scam. The abarxloned Somerset Mine has workings is the C•Seem and B- <br />Seam <br />The C~esm workings arc approximately 175 feet below the D-Seam, andthe 8-Beata weakings are <br />approximately Z50 feet below the D.9eam. The Somerset Mine CSeam Portal elevation in the F1k Creek <br />dtaiaage is at approximately 6150 feet. If the Somerset C-Seam workurgs were completely flooded to the <br />outcrop, seepage would begin m appear at these portal locations. Because this outlet exists, it is unlikely <br />that the water level could ever backup hiQhcr than the 6150' elevatiat. <br />Currently, there era workings is the EIk Creek Mine that are below the 6000' elevation. As stared, the <br />worst posstble case is that water would backup in the Somerset Mine to afl elevation of 6150'. But this <br />does not mean that all worldags in the Elk Creek Miae that are below the 6150' elevation would ba in <br />danger. Both the CSeam end the D-Seam are dipping to the northeast at approxitnatrly 5%. This nreana <br />water would have to migrate laterally for over 3500 feet to eater the EDc Creek Mate (See Drawing 2). <br />Although it is possible for water to accomplish this feat given enough bead and migrating in the same <br />strata, it is highly ualil~ly m occur whoa flee water aunt pass through many diffiaeat layers of strata, <br />including the finely granted Bowie Sendstoae member directly below the D-seam, and the finely grained <br />sitalea found is the interbwden. These shales arc characterized by a very low permeabiliry. There would <br />also ba a certain amount of head necessary to face the water through the strata. At the proposed wamr <br />iajeotion location, for example, the maximum pressure that could be maintained would be apprmcimately <br />150 feet of head, err 65 P51. It is unlikely that this amount of pressure could force water through many <br />low permeability seams for a diataace of 3500 feet <br />Supposing that the water does not travel ]aterally, but takes the shortest path firom the GSeam to the D• <br />Sears, and coald peen though all of the interbedded shales and sandstones, this still would not pose any <br />danger because the interburden distance is greater than the maximum head of the water. It is physically <br />imposatble for water to reach the D,Seam worlongs_ <br />Oxbow Miainq has not identified arty major faults, joist st<rrcturea, or other cbamels sear the proposed <br />water injeettoa location. TJader the worst case sacnerio with the Somerset Mine flooded to its maximum <br />level, end supposing that a path along a geologic structure were present, the amount of imzrburden is still <br />so greet that migration of water from the Somerset Mine to the Elk Creek Mine is unlikely. My water <br />seen in the Elk Creek Mine would show up as a seepage at best, and not a massive, uncontrollable <br />inundation. <br />Oxbow Mining does not anticipate any problears associated with pumping water into the abandoned <br />Sotnersee Mine. We request approval of this waste water disposal plea. If you have any questioae, please <br />contact this otTice at 970/929-5122. <br />Yours truly, <br />Randy I,itwiller <br />Mine Matea,+er <br />