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<br />Technical Revision No. 80 ............................................................................................................ Page 4 <br />September 22, /997 <br />sealed sump can be pumped out when it accumulates to the level of the seals (where it can <br />then be reached by pipelines and/or pumps already constructed through the seals). <br />The locations and sources, if known, of inflows are described and/or aze shown on mine <br />maps submitted with MCC's Annual Hydrology Reports. Further discussion of the "small" <br />capacity sumps is provided in the TR application (page 2.05-238). Note that the total <br />volume of all of the small capacity sumps is insignificant in comparison to the "large <br />capacity sumps". <br />To reiterate, MCC does not believe that Rule 4.05.16 applies to the management of water <br />within an underground mine, including the use of small capacity or lazge capacity sumps <br />within active or sealed workings of the same mine. With the Division's interpretation, all <br />mines would need prior approval from the Division to handle any and all water generated or <br />encountered underground. This would create overwhelming burdens for both the Division <br />and mine operators and cannot be what was intended by this rule. We appreciate the <br />Division's pragmatic approach of focusing only on "large" water matters, but renew our <br />objection to the Division's interpretation of the rule as applying to the management of a <br />mine's underground water within the underground workings of its mine. <br />3. Please note that the NE Panels and Box Canyon Panels sealed sumps are lap need sumps, as <br />neither have been mined. (Also see the response to question #l.) As these panels have not <br />yet been mined, (longwall mining of the 1NE Panel began the week of September 15, 1997), <br />water has not been "discharged" to this area as asked in this question. There is, however, <br />some operational water and some water from afracture/fault area (shown in the ]996 <br />Annual Hydrology Report) in the 1NE Tailgate that flows down-dip to an operational sump <br />in the northeast corner of the 1NE panel, then is pumped to the NE Tailgate sump (another <br />small capacity sump), and out of the mine to the sedimentation ponds, treated, if necessary, <br />and discharged. <br />4. The inflow/outflow system referred to in the last sentence on page 2.05-239 is one 3-inch <br />pipe through the lower-most seal at Lone Pine (between cross-cuts 6 and 7 of the 7NW <br />longwall panel). This pipe was installed to relieve any pressure build-up from water on the <br />seal (a MSHA requirement). Water flows by gravity and head pressure from one side of the <br />seal to the other and is handled in the mine. The statement on page 2.05-239 is partially in <br />ettor, as the two 6-inch pipes are in the cross-cut #14 seals in the 1NW tailgate, which is <br />discussed two paragraphs above this one on page 2.05-239. This inflow/outflow system <br />was installed to pump water out of the sealed sump and out of the mine when water reached <br />the cross-cut #14 seals. To date, water has not accumulated to a sufficient level to facilitate <br />pumping and, therefore, MCC has not pumped any water from this location. The permit <br />page will be corrected accordingly. <br />5. Prior to November 1996, all of the B East Mains fault inflow water was managed in the <br />mine with operational sumps and then pumped outside to the sedimentation ponds, treated, <br />