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George V. Patterson, Energy Fuels Coal, Inc. <br />Page 8 <br />February 12, 2015 <br />b) Groundwater Rights <br />Rule 4.05.15 requires that the operator "...shall replace the water supply of any owner of a vested <br />water right which is proximately injured as a result of the mining activities in a manner consistent <br />with applicable State law." The PAP addresses the potential for mining to impact existing <br />groundwater rights (page 2.05.6 -28). Three pre- existing groundwater rights are described within the <br />permit and immediately adjacent areas: the Corley Mine Well, the Corley Company Well, and the <br />Thompson Well. The Corley Mine Well and the Thompson Well were each completed in old mine <br />workings in the Rex Carbon seam, which is — 300' above the Vento seam and —400' above the <br />disturbed interval. The Corley Company Well was completed in the Raton Formation, higher still in <br />the stratigraphic column. As has already been discussed, there is a negligible chance that the <br />Southfield mine could have dewatered the strata which the wells associated with these water rights <br />are completed in. <br />It should be noted that the PAP information is not entirely consistent with information available <br />from the Division of Water Resources (DWR). Information accessed using the Aquamap tool <br />available through the DWR website6 shows that there is a record of two groundwater rights within <br />the area. The first is named the "Corley Mine Well" (WDID: 1205025) and corresponds to the <br />location of the Corley Mine Well on map 12. The second is named the "Rex Carbon Drill Hole" <br />(WDID: 1205680); it was decreed to John E. Thompson on January 24, 1974 and corresponds to the <br />location of the Thompson Well on map 12. Note that a third structure, named "IL EFC 2" (WDID: <br />1205400) was inventoried by DWR but does not have an associated water right; this structure <br />corresponds to the North Dewatering Well, which was latterly re- designated as MWNW and is <br />discussed in detail below. <br />The Division is unaware of any groundwater rights owned by South Central Land and Mining, <br />LLC, or K2T, LLC, or any individuals associated with the Vento group. <br />Rule 2.04.7(1)(b) requires that the operator shall "...also provide well locations and reported yields <br />from all wells within the proposed permit and adjacent areas which are registered with the Office of <br />the State Engineer ". On page 2.04.7 -13 of the PAP, table 11 contains a list of wells in the permit <br />and adjacent area however it appears that the table may be out of date. Appendix A gives a list of <br />well permit applications within 1 mile of the Southfield Mine permit boundary, downloaded from <br />the DWR database on January 12, 2015. The list has been filtered to remove records where the <br />permit application status is "abandoned ", "denied" or "expired "; where the owner is EFCI; or where <br />the permit was issued after 2000 (when the mine was closed). The remaining list comprises 42 <br />records. <br />Please update table 11 of the PAP. If any wells have been damaged please describe the extent <br />to which operations at the Southfield Mine impacted the well and any measures EFCI have <br />taken to mitigate the impact. If replacement wells have been drilled, please include relevant <br />information about them. <br />