2013-09-16_REVISION - C1981014 ‎(3)‎

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 9/16/2013
• Doc Name: DRMS response to Objection letters received August 21, 2013
• From: DRMS
• To: Linda Saunders
• Type & Sequence: TR40
• Email Name: JHB
• Email Name: DIH
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
C O L O RA D O
D I V I S I O N o f
Denver, Colorado 80203
RECLAMATION
Phone: [phone]
M IN I NIN G
N
FAX: [phone]
SAFETY
September 16, 2013
John W. Hickenlooper
Governor
Linda Saunders
I2T
Mike King
Executive Director
34315 Forest Park
Elizabeth, CO 80107
Loretta E. Pineda
Director
Re: Southfield Mine (Permit No. C- 1981 -014)
Technical Revision No. 40 (TR -40)
DRMS response to Objection letters received August 21, 2013
Dear Ms. Saunders:
The Division received your objections to Energy Fuels Coal Inc.'s application for a technical revision
(TR -40) for the Southfield Mine on August 21, 2013. This revision proposes to cease monitoring in
monitoring well MWNW. In your objection letter you brought up concerns applicable to the TR -40
application and some not applicable to the TR40 application. The Division will attempt to answer your
concerns. Your concerns are numbered, with the Division's responses following.
Energy Fuels Coal Inc (EFCI) should not be allowed to remove monitoring well MWNW from
their approved water monitoring program. EFCI has requested to no longer monitor MWNW in
the Southfield Permit area on our property. This monitoring well intercepts the Southfield Mine
Workings in the Red Arrow and Jack O' Lantern Coal seam. EFCI needs to continue monitoring
MWNW as part of their Hydrologic Monitoring Plan according to regulations 4.05.13(1)(a),
4.05.13(1)(c), 4.05.13(1)(e)e(i), 4.05.13(3)(a) and 4.05.13(3)(b). To no longer monitor MWNW
would be non - compliance with these regulations.
DRMS Response: Rule 4.05.13(1)(a): The Division believes that EFCI's proposed water
monitoring plan that would continue to monitor MW23, MW 16 and MW65 continues to meet the
requirements of Rule 4.05.13(1)(a) and provide the appropriate information. DRMS, BBA, and
EFCI do not find that monitoring of MWNW provides additional information not already
supplied by monitoring of MW23 and MW65.
Rule 4.05.13(1)(c): The Division believes that EFCI's proposed water monitoring plan that
would continue to monitor MW23, MW 16 and MW65 would continue to meet the requirements
of Rule 4.05.13(1)(c) and provide the appropriate information. DRMS, BBA, and EFCI do not
find that monitoring of MWNW provides additional information not already supplied by
monitoring of MW23 and MW65.
4.05.13(1)(e)(1): We believe the reference to Rule 4.05.13(1)(e)e(i) was meant to refer to Rule
4.05.13(1)(e)(1). The Division wrote NOV CV- 2013 -002 for EFCI's failure to maintain MWNW
as required by this regulation. TR40 provides additional information regarding why MWNW
does not provide additional information not already provided by wells MW23 and MW65. Based
on this additional information, EFCI is requesting that DRMS vacate NOV CV -2013 -002.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines