2015-04-01_REVISION - C1981014 ‎(2)‎

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 4/1/2015
• Doc Name: Email from Linda Saunders Regarding Hydrology
• From: Linda Saunders
• To: DRMS
• Type & Sequence: TR43
• Permit Index Doc Type: Hydrology Report
• Email Name: RDZ
• Email Name: MPB
• Media Type: D
• Archive: No

4/2/2015 State.co.us Executive Branch Mail - Fwd: 4.05.1 Hydrologic Balance General Requirements and Staff Review of AHR
These wells will determine if the aquifer has been damaged or depleted. Three nearby wells into the Trinadad
Aquifer are Palmer Kirk Locke Mt 680' pumping rate 0.5, Lot 3 Newlin Ridge 680' Pumping Rate 1., and another
new property owner is petitioning the Division of Water Resources to exempt them since they cannot get water
from the aquifers and will have water brought in.
We cannot wait to see if the recharge of the mine at 5 acft per year will occur in 120 years.
Three known wells existed on this property prior to 1980- the one that was at the Vento Building where there is a
sink in the kitchen, one on the south side of Magpie Creek where the remains of the well house and electric pole
still exist and one at the top of the hill above the portal.
My father raised cattle on this property and had water for his livestock.
We need some use of this property after mining.
MWNW needs to be replaced to determine if the mine is filling up with water and monitored property.
Since MWNW was never a monitoring well, EFCI was not in compliance with the Hydrologic Monitoring Plan
according to regulations 4.05.13(1)(a), 4.05.13(1)(c), 4.05.13(1)(e)3(I), 4.0513(3)(a) and 4.05.13(3)(b).
It seems that there was not a requirement to test the ground water when the regulations state that this would be
done to ensure water quality.
The only well that has been tested is the upslope well MW23 at 150 -170 feet is in a coal seam not into ground
water below.
The 3 abandoned wells on our property need to be sealed and closed property and all auger holes need to be
sealed to prevent drainage.
It seems that a mining company can report a well dry (MW 8 and MW 16), block it (MWNW) or mine through it
(MW 10) and still be in compliance with the regulations.
Disturbances to the prevailing hydrologic balance have not been minimized.
Please consider my concerns in your review and requirements that EFCI will have to comply with immediately.
From: [e-mail]
To: tena aol.com; [e-mail]; [e-mail]
Subject: 4.05.1 Hydrologic Balance General Requirements and Staff Review of AHR
Date: Sat, 21 Mar 2015 23:21:31 -0500
In the December 11, 2001 document EFCI states "EFCI's mining and related
activities have been planned and conducted to minimize disturbance to and
prevent long term adverse changes in the prevailing hydrologic balance in the
mine..."
The relationship between planned mining and reclamation operations and the
hydrologic balance are detailed in Section 2.05.6 Mitigation of Mining Operation
Impacts. This section identifies all potential hydrologic impacts and evaluates
proposed control and mitigation measures. The discussion in Section 2.05.6
effectively justifies the conclusion that there will be no long term adverse changes
in the hydrologic balance in the Southfield mine
In Robert G Biddle June 15, 1984 permit renewal review for Dorcheter No. 1 Mine
( the predecessors of EFCI) states "The mine is presently incurring water sources
in both the north and southern sections of the mine. No quantitative studies have
been undertaken to date."
Stipulation No. 3
Within 180 days of permit issuance the operator shall provide documentation that
the appropriate filings have been made with the State Engineers Office or
Applicable Water Court Regarding the storage and consumptive use of water at
the mine. Energy Fuels applied for 12508 -AD BUT THE APPLICATION WAS
DENIED. EFCI continued to use it until 1995. It was tagged by the Division 2
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