2015-07-15_GENERAL DOCUMENTS - C1981014 ‎(2)‎

• Permit No: C1981014
• IBM Index Class Name: General Documents
• Doc Date: 7/15/2015
• Doc Name: Response to Dr. Corley
• From: DRMS
• To: W.D Corley
• Permit Index Doc Type: Public Correspondence
• Email Name: LDS
• Email Name: RDZ
• Media Type: D
• Archive: No

7/29/2015 State.co.us ExecL#ive Branch Mail-Re:Monitoring well
STATE, OF Hernandez - DNR AI sha <al [e-mail]>
� �O L R�'Al u , Y Y
Re: Monitoring well
1 message
Simmons - DNR, Leigh <[e-mail]> Wed, Jul 15, 2015 at 8:34 AM
To: "W D Corley, Jr." <[e-mail]>, Alysha Hernandez - DNR <[e-mail]>
Cc: Rob Zuber- DNR <[e-mail]>, Mike Boulay - DNR <[e-mail]>
Dr Corley,
Thank you for the additional information. We will certainly take the points you raise into account as we proceed
with this permitting action.
It would be premature for me to give you a more substantive response at this time, but we expect to resolve the
issue soon.
Leigh Simmons
Environmental Protection Specialist
COL011RADO
,�.:, Division of 1Recta rnat�iion.,
:unin and Safety
Department of Nal.ural 1�esources
303.866.3562 x 8121 I F 303.832m8106
1313 Sherman Street, Room 21 , Denver, CO 80203
[e-mail] I http://mining.state.co.us/
On Wed, Jul 15, 2015 at 8:14 AM, W D Corley, Jr. <[e-mail]> wrote:
Mr. Simmons,
The Energy Fuels revision application for drilling a new monitoring well presents a dilemma for the Division
with one landowner insisting on a new well and the second landowner insisting that drilling this well is unsafe.
The Division has responsibilities for both viewpoints
Since The Corley Company's underground fire started prior to almost all of the current DRMS inspectors I
would like to recount some of that fire history. In about 1980 neighboring Harrison Western (HW) at
their Shamrock Mine had a fire start in their waste pile. The Division instructed HW to move the waste pile so
that the fumes would not enter the mine's ventilation system. HW had no convenient location to move the
burning material so they contracted with GEC, the company leasing and surface mining our coal, to fill
unreclaimed strip pits on our property. The division approved this contract and transportation of the burning
material despite the fact that GEC had no right of assignment under their lease. Further, we were never
notified of this contract and never gave our approval. The exposed coal seam at the toe of the strip pit was
never covered, and the burning waste caught the coal on fire. This is not only my opinion but the judgment of
the District Court in GEC vs. Harrison Western. GEC attempted to extinguish the underground coal fire, and it
went bankrupt as a result. The Division then attempted extinguishing the fire with a series of drill holes and
blowing pea gravel into the void. We were then notified by the Division that the fire was out. History has
proven now 35 years later that the Division's conclusion was incorrect because the fire is still burning.
In my previous emails objecting to the new monitoring well drilling, I outlined two possible sources of ignition
of methane if there is methane in the Southfield Mine void. One is from possible sparks from the drilling of
well and the other is from the underground fire. Unless the Division has a detection method unknown to me,
there is no way to determine the extent of this fire. Unless the Division can state unequivocally that there is
zero chance of a methane explosion from the drilling it must be assumed that there is a possible explosion
chance, no matter how unlikely. Then considering the lack of information that may be derived from a new
monitoring well, the risks seem to far outweigh any possible benefit. Specifically, water will be detected or not
in the well. If there is water, it will be contaminated or not. If the water is contaminated, as expected, there is
no way to purify the water in the void and keep it pure since it is in contact with the remaining coal. Finally,
knowing the water level in the void serves no useful purpose. What can be gained from any of the water or
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