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2015-07-13_REVISION - C1981014
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2015-07-13_REVISION - C1981014
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Last modified
8/24/2016 6:09:06 PM
Creation date
7/15/2015 7:16:53 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
7/13/2015
Doc Name
Response to Initial Adequacy Review
From
Energy Fuels Coal, Inc
To
DRMS
Type & Sequence
TR46
Email Name
RDZ
Media Type
D
Archive
No
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Mr. Leigh Simmons July 9, 2015 Page 3 <br />in fact, through no fault of EFCI, the likely cause of the casing damage to MW -NW as the <br />result of a roof fall, leading to the very situation that we are in now. EFCI does not <br />believe that offsetting the new well a short distance away invalidates modeling efforts or <br />the mining atmosphere in any part of the mine. Furthermore, the significance of any data <br />taken at MW -NW is limited as it is a single data point. Annual Hydrology Reports <br />submitted since MW -NW was incorporated into the water -monitoring plan have <br />repeatedly documented (18 separate readings) that the mine was dry, with no problems or <br />casing -related issues encountered until 2012. The purpose of groundwater monitoring at <br />this time is to detect whether groundwater is infiltrating the mine workings generally to <br />determine the effect on groundwater hydrology, not whether water exists at isolated <br />locations in a local sump. A new well at the proposed well location for MWNW-2 is <br />within a few feet of elevation of MWNW 1 and will serve the purpose of detecting <br />groundwater inflow generally as well or better than MWNW 1. <br />3. DRMS concern <br />Please survey the area for recent evidence of underground fires. <br />EFCI response <br />EFCI previously addressed the proximity of current and past mine fires in the Risk <br />Evaluation that was submitted to the Division (via email 6/12/2015 10:41 am). This <br />information was in response to questions raised by the DRMS on May 27, 2015 in a <br />meeting with Gorham Energy Consultants, acting on behalf of EFCI. Please review this <br />information. EFCI is well aware that the Inactive Mines Program routinely drill into <br />active mine fires. However, EFCI's main concern is not drilling into any existing mine <br />fire, but avoiding the potential of starting a new underground mine fire. This is also of <br />significant concern to the adjacent landowner, Dr. Corley, as you are well aware based on <br />written objections previously submitted to the DRMS. EFCI suggests the DRMS visit the <br />location of the GEC mine fire at the next opportunity. <br />4. DRMS concern <br />Please review the proposed drilling method in the light of the results gained <br />by sampling air drawn from the mine workings, and of the survey of the area <br />for evidence of recent fire activity. <br />EFCI response <br />EFCI has considerable drilling experience and is confident in the knowledge and <br />experience of the contractors named in the cost estimate provided to the DRMS on May <br />27, 2015. As you know, the costs to re -drill this well are considerably more than normal <br />
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