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• PB-3-2 There are a number of water management issues that are not adequately <br />described or addressed in the reclamation permit. <br />2) What are the water rights implications related to pumping the Cash Mine <br />well.... <br />The Cash Mine has been historically dewatered as necessary via a deep water <br />well which was drilled 552 feet by Itech Environmental into the Cash Mine <br />shaft at the 7th level elevation. Adrian Brown discussed this very issue with the <br />SEO in 2006 and 2007. During the Adrian Brown's major hydro-geologic study <br />of the ground water, the SEO clearly indicated that in order to identify the actual <br />inflow rate of all waters into the mine, recharge rate testing was allowed <br />provided the water was not put to beneficial use. During MRV's operation, <br />water is infrequently pumped to the mill tailings pond and evaporated. The well <br />pump is rated at 33 gpm and the discharge rate from the 2-inch hose at the pond <br />is approximately 22 gpm. <br />It is MRV's belief that at no time has any material injury to any other party's <br />water rights existed. MRV does not have permission to use this water for . <br />beneficial use, and we do not. None of this water is or was used in the mill <br />under MRV's control. Please refer to the above statements regarding Steen's <br />violation of the JV contract. <br />• MRV does have ownership of 20 shares of the LeftHand Ditch Company, and if <br />we ever need make-up water in the mill we can truck it or plumb it from that <br />source as was done historically during Steen's operations. This would require <br />significant regulatory review, as you have indicated via questions raised during <br />the TR06 review for this permit specifically regarding piping and permit <br />boundaries, not to mention additional EPA-UIC oversight. <br />PB-3-3 3) Describe the locations, purposes and uses of each of the pipes, ... <br />The only cables are a low-voltage telephone line from the office and mill to the <br />core shack, 3rd level portal and into the underground, and a power cable from <br />the core shack to the escape way adit which provides power for mine <br />ventilation, etc. <br />Since your inspection visit on June 12, 2009, we have dragged most of the <br />assorted hoses and pipes out of the bush. There are still numerous hoses and <br />pipes that were installed by Steen to pump water via the pumps still located <br />below the 3`d level in the Cash shaft. "Nocturnal emission" was the phrase that <br />Steen used while conducting this nefariousness, during the 1980's and 1990's. <br />These pipes have not been utilized or even touched by MRV during the <br />continual site cleanup. <br />0