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1 <br />' Mountain Coal Company, LLC <br />West Elk Mine <br />Post Office Box 591 <br />Somerset, Colorado 81434 <br />' Telephone 970929-5015 <br />Fax 970 929-5595 <br />' July 24, 1998 <br />' Mr. David Berry <br />DIVISION OF MINERALS AND GEOLOGY <br />' Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Re: West Elk Mine, Permit No. C-80-007, NOV No. CV-97-022 <br />III IIIIIIIIIIIIIIII <br />999 <br />Fitl=e`;cl`~tli <br />MY~ <br />' Dear Mr. Berry: <br />As you know, Mountain Coal Company, LLC ("MCC") has conducted additional investigations <br />' and analyses to provide the necessary information and documentation to show that MCC was not <br />responsible for the water flow nor the November 1997 landslide activity at the Bear No. 3 Mine, <br />as alleged in the above-referenced Notice of Violation ("NOV"). It is MCC's understanding that <br />' the water chemistry and geotechnical issues, per memoranda by Harry Posey, Jim Burnell and Jim <br />Pendleton, attached to your March 30, 1998 letter, were resolved during the June O1 and 03, <br />' 1998, meetings with the Division and MCC's consultants. Further resolution of the hydrologic <br />and hydraulic issues occurred during our June 30, ] 998 meeting. To document and supplement <br />these meetings, MCC provides the attached meeting summaries, tables and exhibits, as well as the <br />' following brief responses to the questions the Division had posed in your March 30, 1998 letter. <br />With this documentation, MCC understands that the Division will be prepared to vacate this <br />NOV. <br />' The water flow at the Bear No. 3 Mine ("Bear") in the vicinity of the sealed Edwards Mine portal <br />is described in your letter as being "groundwater ... expressing as the new discharge". As <br />' discussed during our June 30th meeting, substantial evidence demonstrates that water has been <br />accumulating in and flowing from the abandoned Edwards Mine (B-seam workings) for a number <br />of years, and therefore is not a "new" source of water. Elevated electrical conductivity and total <br />dissolved solids have been measured since 1986 in Bear's alluvial monitoring well AA-1, located <br />at the base of and since covered by the subject landslide. Bear's consultant has also described the <br />water in AA-1 as being a "tea-stained" color, unlike the water in well AA-3 located a few hundred <br />feet away from the landslide toe, but similar to the stained water now flowing from the Edwards <br />Mine portal area. Bear's permit (page 2.05-556) states that the "source of the contaminants (in <br />AA-1) is apparently the coal stockpile." Without a fairly constant flow of water through Bear's <br />' coal stockpile, it is unlikely that leachate from the coal stockpile could be the source of this <br />historic contaminant. A Division inspection report from August 1995 includes a description by <br />' Basil Bear of an inflow with a very high TDS in the mine's coal stockpile drawdown tunnel as <br />"...coming from the abandoned workings of the Windjammer Mine" (a.k.a. the Edwards Mine). <br />