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K2T LLC <br />South Central Land & Mining LLC <br />19 May 2014 <br />Page 5 <br />Columbine Coal CO before EFCI Permit 12508 -AD (Application Denied) 7/22/1991 Energy Fuels <br />Coal Inc <br />MWNW and MW 16 and MW23 have not been permitted as required by the Colorado Division of <br />Water Resources. <br />Response: MW16 and MW23 were designed, permitted by the Division and constructed to monitor <br />coal seam groundwater to determine if the mining operation caused any significant decrease in the <br />coal seam groundwater quality. <br />The well that was used originally to dewater the coal mine was commonly known as the "North <br />Well". The permit application to the State Engineer's office for the North Well was denied as <br />indicated. As a result, the North Well was converted to a groundwater monitor well now known as <br />MW-NW <br />Historically, monitoring wells at coal mines have not been subject to construction or operation <br />permitting requirements for water wells under the jurisdiction of the State Engineer's Office <br />( "SEO "). However, in recent years the Division and the SEO have begun requiring that monitor <br />wells go through a SEO permitting process. As part of the abatement process under the Modified <br />NOV, EFCI has filed the required permit applications with the SEO. <br />Item No. 4: <br />Aquifer. There was an alluvial aquifer under this area which was noted by Robert G Liddle, <br />Reclamation Specialist for the Division of Mining in his report on June 15, 1984. "The mine is <br />presently incurring water sources in both the north and the southern sections of the mine. However <br />the mine inflow study to be conducted by operator will provide valuable data in the future in <br />impacts from the mining." Rule 2.07.6 (2) (c) requires the Division to make an assessment of the <br />probable cumulative impact of all anticipated coal mining in the general area on the hydra logic <br />balance and to make a finding that the operations proposed in the permit application has been <br />designed to prevent damage to the hydra logic balance. "Currently, with 80% of our property being <br />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 <br />drill a well into the current ground water. Before EFCI's final bond release, the new well should be <br />drilled down to ground water to determine the effect on the ground water level that has been <br />damaged. At a board hearing many years ago, a new well was requested but the staff has not taken <br />any action. <br />Another reason that a new well into ground water (not a monitoring well) needs to be drilled is to <br />test the water for contaminants. The only well currently being tested is MW23 at 150 feet and into a <br />coal seam. The Vento family has expressed concerns about the manganese, iron, calcium and <br />sulfates reported in MW23 that do not comply with Secondary Water Standards. MWNW (formerly <br />the North Well) needs to be replaced to determine if the mine workings are filling with water. <br />According to Janet Binns in her May 15 2012 Inspection Report, Rehabilitation of MW -NW is <br />