2013-12-16_REVISION - C1981014 - Laserfiche WebLink

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10. EFCI's former mine engineer, Allen Weaver met the Corley Company's ranch manager, Mr. Ray Kirby at the well site (Well No. 119459) during 1992 to investigate the status of the well. Weaver and Kirby probed the well at that time and determined that the well was dry. According to records, the well is shallow having a depth of 100 feet and had a rate of one (1) gallon per minute. Subsequent to the inspection of the well by Mr. Weaver and Mr. Kirby in 1992, there is no known concern or complaint of record until recently, some 20 years later. Subsequent to EFCI's previous submittal (April 3, 2013), information has become available from an in depth Hydrologic Review of Southfield generated by Mr. Mike Boulay, hydrologist for the DRMS. Mr. Boulay states that drawdown effects to the Corley Company well would not be expected to be present [pertaining to mining activities beneath the well]. DWR well records indicate the well produced approximately 1 gallon per minute. Mr. Boulay's comments concerning the Corley Company well can be reviewed under the subject of "Adjudicated Wells Within the Permit and Adjacent Areas" on Page 9 of Mr. Boulay's review which is on file with the DRMS. 11. EFCI's commitment in the approved permit is to conduct a field reconnaissance of boreholes prior to final bond release (page 2.05.4 -30). Given the economics required for organizing, scheduling, managing, mobilizing and demobilizing equipment to complete the final reclamation tasks prior to final bond release, EFCI intends to perform required tasks in one completion operation near the end of the designated Reclamation Liability Period. On page 2.05.4 -30 of the approved permit, EFCI commits to sealing open boreholes and wells prior to final bond release. A field reconnaissance of respective boreholes and wells will be conducted prior to the sealing operations of the boreholes and wells. In the Division's letter of 10- 11 -13, the Division references Rule 4.13, Contemporaneous Reclamation. Rule 4.13 pertains mainly to backfilling, grading, topsoil replacement and revegetation. As documented in the Southfield Annual Reclamation Reports (ARR's), contemporaneous reclamation occurred throughout the mining operations as the Refuse Disposal Area (RDA) was expanded at the site. As previously submitted, EFCI will perform a field reconnaissance and seal respective boreholes and wells prior to final bond release as approved in the permit document. Based on records searches and reviews, EFCI compiled an inventory report during 2007 (MT5) and again during September, 2013, of boreholes and wells that are the committed liability of EFCI. The latter report, dated October 3, 2013, included the available Drill Hole Abandonment Reports. Copies of the reports were submitted to the DRMS during the reports respective time frames, 2007 and 2013. As stated in the cover letter of the