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NANCE: Piezometric head is basically that level to which the artesian water level would rise. <br />We express it as a feet above sea level. <br />BUNN: Okay. One of the things you say in your memo, and it was in response to one of the <br />concerns raised at the December 6' meeting was, and I'm quoting, "Due to the higher <br />piezometric head in the fresh artesian aquifer than in the overlying saline groundwater, there is <br />no possibility that the saline groundwater will move downward and enter [into] the fresh artesian <br />aquifer." Can, and I think it's what you've been explaining. I just want to make clear. Explain <br />why it's impossible for the overlying salt water to move down into the fresh water. <br />NANCE: The salt water basically has a level at sea level, whereas this thing is possibility 20 feet <br />above sea level, so it's going to be forcing water out of the borehole into the formation rather <br />than the reverse. <br />BUNN: And, can you think of any circumstances under which salt water could contaminate the <br />underlying freshwater in the Mauna Kea lavas where Pi`ilani is planning to drill? <br />NANCE: As I say, when we're open borehole, we're flowing up, let's say the well got finished <br />and now we're sealed off from the salt water above and for whatever reason somebody decided <br />to pump 40 million gallons a day rather than a 100 gallons a minute, grossly over -pumping in <br />that location, in that case, we might pull the salt water up from the bottom as a result. We're not <br />designing the well, we're not going to actually be [inaudible] impossible to do. <br />BUNN: And, can you quantify please what you mean by grossly over -pumping in, relative to the <br />plant pumping which is .2 mgd? <br />NANCE: You know, tens of millions of gallons a day. <br />BUNN: Now, we were talking about the possibility of salt water contaminating the underlying <br />fresh water. What about the reverse? Is it possible that the underlying fresh water could <br />contaminate the overlying Mauna Loa Aquifer? <br />NANCE: Well, contaminate is probably the wrong word because we think of this as a much <br />higher quality water than what the salt water and brackish water that exists up here, so—it's <br />going to flow into it. You can call it contaminate it, but I would call it improving it. <br />BUNN: Okay, and again, that flow is temporary <br />NANCE: —Right <br />BUNN: just until the casing is installed <br />NANCE: until it gets sealed off, yeah. <br />CLARKSON: Can I ask a question? What is the possibility that the barrier, the cap soil is a <br />hundred percent continuous over the entire Mauna Kea Aquifer? Isn't it likely that periodically <br />EXHIBIT D <br />16 <br />