ENFORCE22703

• Permit No: C1980007
• IBM Index Class Name: Enforcement
• Doc Date: 10/10/1997
• Doc Name: REVIEW OF TECHNICAL REVISION 80 WEST ELK MINE PN C-80-00
• From: J E STOVER & ASSOCIATES
• To: DMG
• Violation No.: CV1997022
• Media Type: D
• Archive: No

J. E. STOVER ~ ASSOCIATES
2768 COMPASS DRIVE, SUITE 101
GRAND JUNCTION, COLORADO 81506
PHONE: [phone], FAX [phone]
MINE ENOINEERINO
MINE RECLAMATION
October 10, 1997
Mr. David Berry
Division of Minerals and Geology
1313 Sherman Street, Room 215
Denver, CO 80203
Re: Review of Technical Revision No. 80
West Elk Mine Permit No. C-80-007
Dear Mr. Berry:
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CONST. MANAGEMENT
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The DMG's letter to me dated September 29, 1997 provided a copy of the text portion
of MCC's responses to the DMG's adequacy review for Technical Revision No. 80 (TR-
80). MCC's responses addressed Bear Coal Company's concerns about TR-80 which
were expressed in my letter to the DMG dated July 15, 1997. On behalf of Bear Coal
Company, following are its comments on MCC's thirty page letter to the DMG dated
September 22, 1997.
1. MCC presents some interesting timing data that was previously unknown to
Bear. MCC's 1 NW -SNW longwall panels were sealed in May of 1995. The
sealed panels created the NW Sealed Sump. Until May of 1995 the small
capacity sumps located in the longwall panels, up-dip and adjacent to the Bear
No. 3 Mine, were routinely dewatered. Once these panels were sealed, water
was collected and stored in the sumps and the longwall panels. MCC states that
operational water as well as minor inflow water from the 8NW panel naturally
flowed to the NW Sealed Sump. Presumably, MCC had no reason to minimize
the amount of water that flowed to the NW Sealed Sump.
Bear states in its 1995 AHR that beginning in June of 1995, The Bear No. 3
Mine began to notice a measurable amount of water building behind the seals in
the 3rd West Section. This unanticipated flow coincides perfectly with MCC's
sealing of its 1 NW -SNW panels. MCC sealed the panels in May 1995 which
allowed increased quantities of water to be stored in the NW Sealed Sump. The
resultant seepage from the NW Sealed Sump reached Bear's 3`d West Section
during June 1995. The fact the flow from the West Elk mine to the Bear No. 3
Mine increased from 16 gpm to 30 gpm during the following year would be