Laserfiche WebLink
COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Linda Saunders <br />34315 Forest Park <br />Elizabeth, CO 80107 <br />July 30, 2015 <br />Re: DRMS Decision to Vacate NOV CV -2013-002 <br />Dear Ms Saunders, <br />Enclosed please find a copy of the Division of Reclamation Mining and Safety's <br />Decision and Rationale for vacating NOV CV -2013-002. As you are aware, in an effort to abate <br />the NOV EFCI submitted technical revision 46 proposing a plan to replace MWNW with a new <br />monitoring well. During the Division's technical review of TR -46 the Division weighed the <br />benefit and value of the information gained from establishing a new monitoring well against the <br />considerable safety, health, environmental risk, and expense of drilling a new well. Ultimately, as <br />explained in detail in the decision document, the Division is of the opinion that it is technically <br />infeasible and economically unreasonable for the operator to drill a new monitoring well in an <br />effort to abate NOV CV -2013-002. The Division believes that any additional water quantity <br />and/or water quality information that might be collected from a newly -drilled monitoring well is <br />outweighed by the considerable health and safety risks associated with drilling a well into a void <br />assumed with reasonable certainty to contain explosive levels of methane and the unreasonable <br />cost associated with drilling a new well. <br />Based on a totality of the circumstances, information provided by EFCI, and the <br />Division's technical expertise that it is technically infeasible and economically unreasonable for <br />the operator to drill a new monitoring well, the Division is vacating NOV CV -2013-002. <br />In an effort to further explain the rationale related to this decision the Division would like <br />to coordinate either a conference call or a meeting with you, at your convenience. The Division's <br />attorney, Jeff Fugate, will be contacting you to discuss the rationale and attempt to coordinate a <br />mutually acceptable time to meet to further discuss this decision, and other matters of concern. <br />Included with this letter are copies of the Division's June 2013 Memorandum, EFCI's Risk and <br />Economic Evaluation to redrill or relocate MWNW, and EFCI's TR46 adequacy response. <br />Please review all of these documents in detail and contact me or Mr. Fugate directly if you have <br />any questions. <br />Yours sincerely, <br />Leigh Simmons <br />-�—cp1O. <br />01 <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining. state. co. us <br />John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director + 1876 <br />