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4/24/2014 State.co.us Eecutke Branch Mail - Request for a formal Board Hearing on MWNW, MW23 and lackof permitting by EFCI <br />AMSTATE OF <br />COLORADO <br />Request for a formal Board Hearing on MWNW, MW23 and lack of permitting <br />by EFCI <br />Linda Saunders <saunders615 @live.com> Thu, Apr 10, 2014 at 1:48 PM <br />To: "rob.zuber @state.co.us" <rob.zuber @state.co.us >, "daniel.hemandez @state.co.us" <br /><daniel.hemandez @ state.co.us>, "david.berry@state.co.us" <david.berry@state.co.us >, Tena Gallagher <br /><tena @aol. com> <br />TO: Division of Reclamation, Mining and Safety Staff and Board <br />From: K2T LLC, Linda Saunders, manager and owner and Tena Gallager, owner <br />RE: MWNW, MW23, and not permitting of wells <br />In the August 18th memo to staff, I indicated that if the staff determined EFCI Inc <br />no longer needed to monitor MWNW, I would like to have this issue heard by the <br />Board. <br />am formally requesting these issue be placed on the Board agenda. <br />Not to monitor MWNW would be non - compliance with the Hydrologic Monitoring <br />Plan according with regulations 4.05.13(1)(a), 4.05.13(1)(c), 4.05.13(1)(e)3(I), <br />4.0513(3)(a) and 4.05.13(3)(b). Janet Binns, Reclamation Specialist notified <br />Energy Fuels of non - compliance with their Hydrology Report and EFCI was fined. <br />How long MWNW has been damaged and not being monitored? <br />Also, MW23 does not meet the requirements of the regulations that it was <br />intended to monitor when it is only 150 feet into a coal seam. There was an <br />alluvial aquifer under this area which was noted by Robert G Liddle, Reclamation <br />Specialist for the Division of Mining in his report starting in 1985. The upslope <br />well should have been drilled to 350 feet to properly monitor the water quality. Dr <br />Corley's monitoring well MW 65 is at 350 feet. There MW23 does not comply with <br />the intent or purpose of the regulations. <br />Finally, none of the wells that were used to dewater the mine and that dried it up <br />were ever permitted as required by the DMRS regulations and was noted in <br />Stipulation 3 of Robert Liddle, Reclamation Specialist for the Division of Mining in <br />Permit Renewal Report C- 014 -81 June 15, 1985 <br />Stipulation No.3 <br />Within 180 days of the permit issuance the operator shall provide documentation <br />that the appropriate filings have been made with the State Engineers office or <br />appropriate Water Court regarding the storage and consumptive use of water at <br />the mine. <br />Permit 8571 -AD (Application Denied) 2/22/1980 Dorchestor Columbine Coal <br />CO before EFCI <br />https:Hniail.g oog le .corNmail /u/0 / ?ui= 2 &ik= b46be11 b9e&�ievi=pt& search= inbox&th= 1454d2faea89e620&si n-1= 1454d2faea89e620 1/2 <br />