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(D) The Division's Assertions Regarding Packer Tests Do Not Support Mine <br />Dewatering and Treatment. <br />The Order erroneously adopted the Division's testimony that the "packer tests performed <br />by [Cotter] are unlikely to be representative of the entire hydrogeologic system," that "fractured <br />igneous and metamorphic rock can have a hydraulic conductivity 100,000 times greater than the <br />packer tests results," and that "rock mass hydraulic conductivity falls within the range of <br />sandstone." Order 125. As explained above, Cotter became aware of the Division's position <br />about packer tests for the first time at the hearing which is a ground for reconsideration. <br />The Division paints a picture of a high-yield sandstone aquifer, which is inconsistent with <br />both site geology and site-specific hydrologic data. The Rebuttal at pages 8 to 10 explains why <br />packer results are representative of the overwhelming majority of the rock mass at the <br />Schwartzwalder Mine and support that the rocks have a very low permeability on the order of <br />10-7 cm/sec or lower. If the rock mass is considered as an equivalent porous media on a mine <br />scale, inflow calculations suggest a bulk permeability of about 2.9 x 10"7 cm/sec. Although the <br />packer test data may not capture small-scale features or individual fractures that dominate inflow <br />to the mine, measurements of steady state inflow to the mine, combined with observation of <br />places where inflows occurred, provide a reliable method to evaluate the entire hydrogeological <br />system. See Cotter Rebuttal, Exh. 1, at 9. <br />The Division's testimony could lead a non-technical observer to believe that permeability <br />at the Schwartzwalder Mine would be similar to permeability in the sandstone and siltstone <br />aquifers in the Denver Basin. See Susan A. Wyman, P.E., P.G., Whetstone Associates, <br />Additional Information Regarding the Schwartzwalder Mine (August 30, 2010) ("Whetstone <br />Report") (attached hereto as Exh. 4). The Whetstone Report sets forth the conclusion at page 5 <br />that hydraulic conductivity of the bedrock near the Schwartzwalder Mine is 1,000 times lower <br />15