2015-07-13_GENERAL DOCUMENTS - C1981014

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EFCI Southfield Mine — 2012 Annual Hydrology Report April 18, 2013 DRMS Inspectors Janet Binns, Dan Hernandez and Lee returned on September 17, 2012, and again lowered the remote camera into the well casing. George Patterson also attended the inspection. The camera showed the wooden block probe located at 354 feet below the top of the casing. Pursuant to the inspection, DRMS issued a written directive to EFCI to remove or clear the partial obstruction in MW -NW or drill a new monitoring well. EFCI maintains that MW -NW is functional for monitoring groundwater and collecting water samples as is stated in the DRMS Inspection Report dated April 17, 2012. EFCI believes that the results of the 1,500 gallon water test proved that the MW -NW casing is open to water flow and that the DRMS concurs that it is open to water flow. Given EFCI's mining knowledge that the roof conditions in the 1 North mine section were historically unstable, the mine roof around the lower portion of the well casing has likely caved. The area between the partial obstruction in the well and the roof of the mine workings, approximately 20 vertical feet, is believed to now be an open void created by a roof fall. In response to DRMS' directive for EFCI to clear MW -NW or drill a new well by December 31, 2012, and with consideration to the foregoing information, EFCI submitted a Technical Revision No.40 (TR -40) Request dated December 21, 2012 which proposes to change the assumed groundwater monitoring and sampling point from the bottom of MW -NW up to the elevation of the partial obstruction. Rather than making a final decision on the TR -40 request, the DRMS ruled TR - 40 as being incomplete, and instead issued a violation (NOV #CV -2013-002, dated January 23, 2013) for failing to maintain the monitoring well as designed. EFCI continues to maintain that the MW -NW is functional as explained above. At this time, the outcome of the NOV is pending. 2012 AHR text doc Page 8