REVISION - 10/1/2009, 7:24:39 AM-JWD

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[In the case of a potential problem], however, the well operator would be expected to correct it. Correcting the problem could mean that the well operator would have to plug a faulty well at his/her expense. In this case, the extent of the prior drilling in the area is highly significant. As demonstrated by the attached map prepared by Powertech and altered only with respect to identifying local roadways, and entitled "Topo and Drill Hole Location Map, Indian Springs and Centennial Uranium Projects", there are literally thousands of historic wells in the areas proposed by Powertech for in situ leach uranium mining, and many wells in the area proposed for injection under the Draft Permit. (Map attached as exhibit 3). In order to discharge its duties under the Safe Drinking Water Act and the APA, the EPA should require the applicant to provide infonnation demonstrating that these wells have been properly abandoned in a manner that will not allow for communication between the injection area and the overlying underground source of drinking water. The concerns with the previous abandonment of these wells are well documented. Indeed, documents suggest that many of these wells were not properly abandoned and could provide a conduit between the aquifers. For instance, a May 19, 2003 letter from Mark E. Hoffman, Project Manager for Exxon Mobil to Tony Waldron, DRMS, regarding reclamation activities at the Indian Springs Prospecting project (attached as exhibit 4 (with attachments)) states: Prospecting was conducted as described in three Notices of Intent to Conduct Prospecting Operations submitted to the Colorado Department of Natural Resources, Mined Land Reclamation Board, dated August 23, 1977, November 10, 1978, and October 27, 1980 (Attachment A). A total of 492 uranium exploration boreholes were drilled during this period. Mr. J.J. Faulhaber, of Alternative Energy, in an interoffice memo, dated May 28, 1985 (Attachment D) summarized borehole abandonment procedures and standards for the Project. Boreholes were abandoned with drilling mud consisting of varying viscosities from the bottom of the hole to ten feet below the ground surface. Cement plugs were installed from ten feet to the surface or two feet below the surface depending upon local cultivation practices. The borehole abandonment standards varied over the course of the Project, but the most stringent standards applied to the 1980 drilling program.... The boreholes were drilled into the stratigraphic horizon that contains the Laramie-Fox Hills aquifer, a regional hydrogeologic unit that spans the base of the Laramie Formation and the top of the Fox Hills Formation. In a letter to Mr. Kenneth Holmes (Mobil), dated February 23, 1982 (Attachment E), Ms. Walker [Colorado Division of Mining] expressed concerns over the use of drilling mud in an interval of an aquifer, and the potential for contaminants in the Upper Laramie Formation to enter the Laramie-Fox Hills aquifer.