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The Division is of the opinion that any additional water quantity and/or water quality information that <br />might be collected from a newly -drilled monitoring well is outweighed by the considerable health and <br />safety risk associated with drilling a well into a void assumed with reasonable certainty to contain <br />explosive levels of methane and the unreasonable cost associated with drilling a new well. Without <br />MWNW-2 the Division will continue to make groundwater assessments based on data from the three <br />remaining active monitoring points, historical records from abandoned monitoring points, historical <br />observations of mine inflows, and historical water quality sampling of mine inflows. Although <br />information obtained from MWNW-2 would be helpful, it is not essential as the Division has other <br />sources to secure water quality/quantity information upon which it can rely. <br />The Division concludes based on the above details and a totality of the circumstances and information <br />provided by EFCI, as well as the Division staff's technical expertise, that it is technically infeasible <br />and economically unreasonable for the operator to drill a new monitoring well in an effort to abate the <br />NOV. Therefore, the Division is vacating NOV CV -2013-002. <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Date of Issue: Jul <br />Virginia Brannon, Division Director <br />C -N V -06A <br />