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An average of 11 analyses of the Allen Seam is as follows: <br />Moisture 0.7 Ash 8.5 <br />Volatile Matter 37.8 Sulfur 0.49 <br />Fixed Carbon 53.0 Btu 13,740 <br />A sulfur form analysis of the Allen coal seam currently being <br />mined has been regarded as typical rather than representative, see Table 5, <br />Sulfur Form Analysis. The analysis reflects the dominant organic sulfur <br />species to be the species. Since the product is removed, and the single <br />sample correlates with the historical proximate analyses above, sulfur <br />forms in the product should be of negligible envirorunental concern. No <br />further analyses are contemplated. <br />No significant aquifers were encountered during the course of <br />development and production at the New Elk Mine. Although sandstones are a <br />dominant lithology in the mine area and generally are regarded as being <br />significant aquifers, Raton Formation sandstones are clay-filled and ' <br />usually do not yield water in appreciable quantities. Permeability testing <br />performed reflects the impermeable character of the sandstone units (refer <br />to Page 17 of Exhibit 8, Hydrology and Geology Information). <br />Given the heterogeneous distribution of the sediments enclosing <br />the coal, Exhibit 9, Overburden and Underburden Analysis, displays a <br />reasonable correlation of chemical risks incident to mining in the separate <br />Allen and Maxwell environments. The E.~chibit reflects the geochemical <br />controls of the quality of water developed during mining and demonstrates a <br />buffer capacity sufficient to limit concentrates of trace metals. That <br />point is further confirmed~in the characterization of the quality of ground <br />and surface waters presented in Exhibit 8, Hydrology and Geology <br />Information, and the evaluation of subsequent data, Exhibit 10, Water <br />Quality Analysis, collected since the hydrology study was completed. <br />J <br />2.04-10 <br />