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<br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Re<ources <br />1 313 Sherman SL, Room 21 S <br />Dem~er, Colorado 80203 <br />Phone: 1303) 860-3567 <br />FTS: 1303) 832-A 106 <br />~II ~I~II~III~I~~~I~ <br />sss <br />STATE OF COLORADO <br />INTEROFFICE MEMO <br />~~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Date: August 5, 1998 cUVefnOf <br />tames 5. Lochhead <br />E ~eanive Dueclo, <br />To: Dave Berry Michael B Lung <br />S/ Divrsion Uirecior <br />From: Harry Posey <br />Subject: Review: Letter report, July 24, 1998 from Mountain Coal Company, LLC <br />to Dave Berry, re: West elk Mine, Permit No. C-80-007, NOV No. CV- <br />97-022 <br />The captioned letter report affirms most of the conclusions expressed in my letter report <br />to you dated March 3, 1998. However, [he latest report adds a new supposition, a <br />possible underground mine ftre, which may better explain some of the geochemical <br />curiosities in the data. <br />The current report does not contain the ordinary sort of information that should be <br />furnished to solidify arguments or evaluate their merit. In this reading this note, you <br />should note that I have not seen a full set of the analyses. <br />In the MCC report, sample values were averaged and diagrams were synthesized to make <br />a presentation the operator purports to be "representative" of the sump and seep waters. <br />Without seeing the original, unsynthesized information, the interpretations cannot be <br />judged either adequate or representative. In addition, this and other reports do not list the <br />volume of water that was pumped from each of the underground water sources. <br />The most recent report provides information and clarification that - [he absence of <br />documentation notwithstanding -could offer a separate and new interpretation. Namely, <br />it is MCC's conclusion that a mixture of sump water from MCC's operations and <br />meteoric water become heated as they pass through [he a mine fire area under the Bear <br />Coal property, then discharge out the Edwards mine portal. <br />I agree with MCC's conclusion that not all of the discharge from the Edwards mine portal <br />could be coming from the underground sump waters. To explain the composition of the <br />Edwards portal seep water, it would be necessary, in my opinion, to dilute the <br />underground sump water 2 to 4 times with meteoric water (rain and snow). Accepting for <br />[lre moment MCC's synthesized diagrams that depict water quality, the dilution water <br />