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., J. E. STOVER 8~ ASSOCIATES _ <br />-r <br />2768 COMPASS DRIVE, SUITE 101 III I II ~ II I II IIII III <br />GRAND JUNCTION, COLORADO 87506 <br />PHONE: (970) 245.4101, FAX 242-7908 999 <br />MINE ENGINEERING <br />MINE RECLAMATION <br />Via Facsimile Transmittal <br />November 24, 1997 <br />Michael Boulay <br />Division of Minerals & Geology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Bear Coal Company <br />Slide & Mine Water Discharge <br />Permit C-81-033 <br />Dear Mr. Boulay: <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />at=G~!~~`c~ <br />NpV 2 $ 1997 <br />alvislun of mplelal5 d 1:e0109?~ <br />rlL~a~ ~Y.A <br />r ~u It4'9Y <br />tl~ p. <br />3 ~° <br />My letter to the DMG dated November 17"' discussed the slide and mine water discharge <br />at the Bear No. 3 Mine. The following information is presented to further inform the DMG <br />of Bear's position and concerns regarding this issue: <br />Bear believes the water flowing from the east slide scarp originates in MCC's NW <br />Sealed Sump and the flow will probably increase and be perpetual. MCC has <br />acknowledged that flows from its NW sump would be introduced to the Edwards <br />Mine. The water appears to be emerging from an old Edwards Mine B-Seam <br />portal. Bear has never noted any spring, damp spots or any indication of water in <br />this area. Vegetation gives further evidence this area has historically been dry. <br />There are no cattails, willows or other vegetation in this area which would indicate <br />a spring or damp spot. <br />2. Mine water that discharges from the property must be monitored and analyzed in <br />accordance with Bears discharge permit. Bear's discharge permit requires weekly <br />field analysis, monthly laboratory analysis and quarterly whole effluent toxicity tests. <br />The financial burden to satisfy discharge permit requirements is significant for a <br />reclaimed mine. If the discharge is perpetual, the financial burden is enormous. <br />3. The slide poses some additional concerns for Bear. A catastrophic slide failure <br />could partially dam the North Fork of the Gunnison River which could flood the Bear <br />No. 3 Mine surface facilities area. Additionally, slide debris is now a constant safety <br />concern for Bear personnel. <br />