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11/17/2014 State.co.us Executive Branch Mail - Fwd: Request for a formal Board Hearing on MWNW, MW23 and lack of permitting by EFCI <br />RE: MWNW, MW23, and not permitting of wells <br />In the August 18th memo to staff, I indicated that if the staff <br />determined EFCI Inc no longer needed to monitor MWNW, I would <br />like to have this issue heard by the Board. <br />I am formally requesting these issue be placed on the Board agenda. <br />Not to monitor MWNW would be non - compliance with the Hydrologic <br />Monitoring Plan according with regulations 4.05.13(1)(a), 4.05.13(1) <br />(c), 4.05.13(1)(e)3(I), 4.0513(3)(a) and 4.05.13(3)(b). Janet Binns, <br />Reclamation Specialist notified Energy Fuels of non - compliance with <br />their Hydrology Report and EFCI was fined. How long MWNW has <br />been damaged and not being monitored? <br />Also, MW23 does not meet the requirements of the regulations that it <br />was intended to monitor when it is only 150 feet into a coal seam. <br />There was an alluvial aquifer under this area which was noted by <br />Robert G Liddle, Reclamation Specialist for the Division of Mining in <br />his report starting in 1985. The upslope well should have been <br />drilled to 350 feet to properly monitor the water quality. Dr Corley's <br />monitoring well MW 65 is at 350 feet. There MW23 does not comply <br />with the intent or purpose of the regulations. <br />Finally, none of the wells that were used to dewater the mine and <br />that dried it up were ever permitted as required by the DMRS <br />regulations and was noted in Stipulation 3 of Robert Liddle, <br />Reclamation Specialist for the Division of Mining in Permit Renewal <br />Report C- 014 -81 June 15, 1985 <br />Stipulation No.3 <br />Within 180 days of the permit issuance the operator shall provide <br />documentation that the appropriate filings have been made with the <br />State Engineers office or appropriate Water Court regarding the <br />storage and consumptive use of water at the mine. <br />Permit 8571 -AD (Application Denied) 2/22/1980 Dorchestor <br />Columbine Coal CO before EFCI <br />Permit 12508 -AD (Application Denied) 7/22/1991 Energy Fuels Coal <br />Inc <br />MWNW and MW16 and MW23 have not been permitted as required <br />by the Colorado Division of Water Resources. <br />hftps://mail.google.com/mail/u/0/?ui=2&ik=e29129fcb5&vi ew =pt &search= i nbox &th= 149bec9da1631 cc4 &si m 1= 149bec9da1631 cc4 3/3 <br />