Laserfiche WebLink
Safety, the property owners expressed concern about the water quality not meeting quality standards and lack <br />of wells from which to take samples. The wells tested high in iron, manganese, and sulfites. Well 10 was <br />mined through. Well 16 was dry starting in 2002, but later was tested in 2004 and 2005 and has been dry since <br />then. Only Well 23 at 157 feet has been consistently tested. When Well 23 was tested in 2008, EF was sited for <br />confusion regarding sampling constituents. EF was asked "to ensure that all future sampling is in exact <br />accordance with the approved plan ". Also the 2009 Annual Hydrology plan was not filed by the due date and <br />EF was cited." <br />In a letter to Rob Zuber on Oct 18th 2013, Linda stated "In the 1995 AHR Mike Boulay states the manganese <br />exceeds the Basic Drinking Water Standards in MW 65 on Dr Corley's property and also on 19/9/96, 3/24/97, <br />and 9/30/97. Yet, the manganese in MW23 was higher than the maximum for Secondary Drinking Water <br />Standards in Dec, 2010 and June, 2011. Calcium and Magnesium were also high during this time as shown in <br />the chart we had in our Citizen's Complaint in June 2012. MW23 does not meet the requirements of the <br />regulations that it was intended to monitor when it is blocked so monitoring equipment can't get an accurate <br />reading. <br />3. Well permitting. The wells that are on this property were drilled by Dorchester Coal the predecessor of EFCI <br />and to our knowledge, none of the wells has ever been permitted. As reported in the annual inflow report, for <br />coal washing in 1984 -2002, EFCI used millions of gallons of water from three wells that the State Water <br />Engineer had refused to permit. Secondly, we would like an explanation of why MW23 and MW 16 are into <br />coal veins. See notes at the end of this letter. <br />Finally, none of the wells that were used to dewater the mine or any of the monitoring wells have ever been <br />permitted as required by the DMRS regulations and was noted in Stipulation 3 of Robert Liddle, Reclamation <br />Specialist for the Division of Mining in Permit Renewal Report C- 014 -81 June 15, 1985. <br />Stipulation No.3: "Within 180 days of the permit issuance the operator shall provide documentation that the <br />appropriate filings have been made with the State Engineers office or appropriate Water Court regarding the <br />storage and consumptive use of water at the mine." Illegal wells that were applied for and not permitted <br />include: <br />Permit 8571 -AD (Application Denied) 2/22/1980 Dorchestor Columbine Coal CO before EFCI <br />Permit 12508 -AD (Application Denied) 7/22/1991 Energy Fuels Coal Inc <br />MWNW and MW 16 and MW23 have not been permitted as required by the Colorado Division of Water <br />Resources. <br />Aquifer. There was an alluvial aquifer under this area which was noted by Robert G Liddle, Reclamation <br />Specialist for the Division of Mining in his report on June 15, 1984. "The mine is presently incurring water <br />sources in both the north and the southern sections of the mine. However the mine inflow study to be <br />conducted by operator will provide valuable data in the future in impacts from the mining." Rule 2.07.6 (2)(c) <br />requires the Division to make an assessment of the probable cumulative impact of all anticipated coal mining <br />in the general area on the hydrologic balance and to make a finding that the operations proposed in the permit <br />application has been designed to prevent damage to the hydrologic balance. "Currently, with 80% of our <br />property being undermined, the alluvial aquifer is no longer at 350 feet. The regulations of the Division of <br />Reclamation, Mining and Safety give the staff the authority and responsibility to require EFCI to drill a well <br />into the current ground water. Before EFCI's final bond release, the new well should be drilled down to <br />ground water to determine the effect on the ground water level that has been damaged. At a board hearing <br />many years ago, a new well was requested but the staff has not taken any action. <br />Another reason that a new well into ground water (not a monitoring well) needs to be drilled is to test the <br />water for contaminants. The only well currently being tested is MW23 at 150 feet and into a coal seam. The <br />Vento family has expressed concerns about the manganese, iron, calcium and sulfates reported in MW23 that <br />do not comply with Secondary Water Standards. MWNW (formerly the North Well) needs to be replaced to <br />determine if the mine workings are filling with water. According to Janet Binns in her May 15 2012 <br />