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George V. Patterson, Energy Fuels Coal, Inc. <br />Page 10 <br />February 12, 2015 <br />• Groundwater in the Vermejo Formation is separated from atmospheric pressure by <br />relatively impermeable material; as such it exists under confined conditions. <br />• The potentiometric surface in the Southfield Mine area is not uniform (as a result of the <br />complex lenticular geology and the presence of many abandoned and flooded <br />underground mine workings). <br />• The regional groundwater flow regime is governed by geologic structure, with movement <br />generally down -dip towards the axis of the Chandler syncline, and parallel to the <br />synclinal axis toward the Arkansas River to the north. In the area of the Southfield Mine <br />the general flow regime is to the north -west. <br />• Local groundwater flow patterns are highly spatially variable, and are subject to the <br />influence of: geologic structure; depressions in the potentiometric surface caused by <br />underground mine workings; and variations in the hydraulic gradient resulting from <br />recharge /discharge associated with perched groundwater reservoirs. <br />• Groundwater recharge in the Vermejo formation occurs both in the narrow outcrop west <br />of the Chandler synclinal axis and in the much broader outcrop further east. <br />• Discharge from the Vermejo formation is to the surface water system of the Arkansas <br />River, to the north. Groundwater contributions from the Vermejo Formation to Arkansas <br />River flows are negligible. <br />In the context of this conceptual model, the utility of water levels measured in a relatively small <br />number of monitoring wells sited around the mine workings is extremely limited. <br />The water level within properly constructed wells completed in a confined aquifer does not <br />correspond to the elevation that water exists at in the ground; rather the level in the well is <br />dictated by the elevation the water exists at (the elevation head) and the hydrostatic pressure <br />caused by the weight of material above it (the pressure head). The resultant water level measured <br />in the well is the total hydraulic head, or "head ". If a well (say MW65) is completed in a confined <br />aquifer with the perforated interval at a depth of 968 -988' below the ground surface and the water <br />level in the well is measured at a depth of 250' it does not mean that another well drilled adjacent <br />to the first will encounter water at 250'. Head values measured at monitoring wells completed in <br />confined aquifers are points on an imaginary potentiometric surface (the term "piezometric <br />surface" is no longer used but does occur in the permit text). This explains why the title "Ground <br />Water Elevations" on the 1987 BBA figure and the "Expected Water Level Recovery" label on <br />the 2014 BBA figure are misleading and why the water level in the vicinity of the mine cannot be <br />expected to ever rise above the elevation of the first low - permeability layer above the roof of the <br />mine. <br />Currently water levels in MW23 are a little less than 10 feet higher than the screened interval in <br />the Red Arrow coal seam. Water levels in MW65are approximately 700 feet above the screened <br />interval in the upper and middle Jack O' Lantern seams. These two monitoring wells indicate that <br />groundwater on either side of the mine has a head above the elevation of the mine workings. It is <br />assumed that the workings have not completely filled with water yet; and in any case the <br />workings are either relatively open or filled with unconsolidated rubble with a large pore volume, <br />