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K2T LLC <br />South Central Land & Mining LLC <br />19 May 2014 <br />Page 6 <br />necessary to meet the approved water monitoring plan In May, 2013 Kent Gorham and Janet Binns <br />determined that there was a blockage in MWNW and they cited EFCI and fined EFCI for non- <br />compliance and indicated that it needed to be repaired or replaced in a timely manner. Energy Fuels <br />requested TR -40: removal of monitoring well MW -NW from the approved water monitoring <br />program and on October 7, 2013, the Division found the elimination of monitoring well MW- NW <br />still allows EF's ground water monitoring program to meet the requirements. We, the land owners, <br />requested a board hearing regarding this issue with a certified letter in August 18, 2013. Then on <br />November 7, 2013, Dave Berry rescinds this decision. This issue has not been resolved to our <br />satisfaction. <br />Sec 2.05.6 VII a plan for the restoration of the approximate recharge capacity of the permit area in <br />accordance with 4.05.12(3) to determine the adverse effects: Does this include depleting an alluvial <br />aquifer and no longer having water available for any future use? The determination of the probable <br />hydrologic consequences required by 2.05.6(3)(b)(IV) indicates the adverse impacts on or off the <br />proposed permit area may occur to the hydrologic balance. Has any use of our property been denied <br />to us? What does this mean to the other property owners along CR15 who rely on well water? <br />Response: The groundwater regime at the Southfield Mine is summarized in several reports, <br />notably the Southfield Mine Water Rights Engineering Report prepared by Bishop, Brogden, & <br />Rumph, Inc. in February 1987 and again recently in the Interoffice Memorandum, dated June 3, <br />2013, from Mike Boulay to Dan Hernandez. <br />The various analyses and reviews all identify that groundwater sources in the mine and adjacent <br />areas generally occur as isolated perched reservoirs either within the stratigraphic sequence where <br />favorable localized lithologic and recharge characteristics exist or where the stratigraphic <br />sequence has been modified by underground mining. Underground mining creates large reservoir <br />areas where variances in hydraulic pressure appear to stimulate groundwater inflows and flooding <br />of the abandoned mine workings. <br />The inflow of the perched groundwater in the area to the Southfield Mine was identified in the <br />original groundwater studies and permit process as a probable impact of the coal mining. Such <br />inflows were monitored and reported throughout the life of the mine. <br />EFCI does not agree that it is obligated to drill a new well and even if EFCI were to agree to drill a <br />new well into the mine workings, the water quality would be the same as the historical water quality <br />data from such perched zones which never has met, and was never expected to meet, drinking water <br />quality standards. EFCI is not required to take any action to cause such water to meet drinking <br />water quality standards. See Interoffice Memorandum, dated June 3, 2013, from Mike Boulay to <br />Dan Hernandez. <br />Item No 5: <br />Lack of reclamation. Most of the shrub plantings failed because they were damaged by wildlife, EF <br />was not required to replant and/or to stake the shrubs or to water them to help them get through <br />