2014-11-06_REVISION - C1981014 - Laserfiche WebLink

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In response to the modification of the NOV, EFCI conducted a second well test during April, 2014 wherein another 1,500 gallons of water was gravity fed into the well to determine if MW -NW was open to water flow. The 1,500 gallons of water flowed down through the partial obstruction into the mine workings at an estimated flow rate (timed volume) of over 100 gallons per minute. Again, the water volume of 1,500 gallons was adequate to fill the well casing almost three times over — again, the water did not back up or rise to within view inside the well casing. The current DRMS inspector, Rob Zuber, was present during the well test. The Division concurs that monitor well MW -NW was open to water flow to the mine workings. The obvious conclusion is, "water out, water in " and only a seepage of water into the well would be adequate for monitoring and water sampling as opposed to the high flow rate that the two well tests proved. In further response to the NOV, EFCI is currently in discussion with the Division and is preparing additional technical information in support of the functionality of MW -NW. It should be noted that given that the requirements and conditions of the Southfield Water Monitoring Program have been satisfied as is demonstrated throughout this Technical Revision and support data and considering that EFCI is in the finalization of the Ten Year Reclamation Liability requirements, EFCI intends to submit a final bond release request to the DRMS in the near future. As documented in the approved Southfield permit, all monitoring wells, which includes MW -NW, are required to be sealed and reclaimed prior to final bond release. Given these requirements and conditions, NOV CV- 2013 -002 becomes a moot point and therefore can be vacated. Concerning Step 2 of the abatement for the NOV, EFCI received the approved monitor well permit from the CDWR and Permit No. 294785 was submitted to the DRMS September 12, 2014. Additionally, approved monitor well permits were received for EFCI's other three monitor wells and were submitted to the DRMS. Following the DRMS' approval of the final bond release request, pursuant to receipt of the final bond release, EFCI will submit the appropriate termination request to the Colorado Division of Water Resources (CDWR) for termination of CDPS (discharge) permit 850045 and CDPS permit 850006. On the interim, related Discharge Monitoring Reports (DMR's) will continue to be submitted to the CDWR until approvals of the discharge permits terminations are final to be in accordance with requirements of the CDWR. Pond inspections will also continue on a quarterly basis which will include an annual certification of the ponds by a Professional Engineer until approvals of the final bond release and termination of the Discharge Permits are received by EFCI. As stated above, Ponds LI and L2 located at the Loadout site are scheduled to be reclaimed prior to final bond release. In accordance with requirements of a Technical Revision submittal, a copy of the proposed public notice (press release) is included in Attachment A. The notice will be printed in the Canon City Daily Record upon approval of the notice from the DRMS. 6 TR -43 Revised: 10/2014