Laserfiche WebLink
The concerns with the previous abandonment of these wells are well documented. <br />Indeed, documents suggest that many of these wells were not properly abandoned and could <br />provide a conduit between the aquifers. For instance, a May 12, 2003 letter from Mark E. <br />Hoffman, Project Manager for Exxon Mobil to Tony Waldron, DRMS, regarding reclamation <br />activities at the Indian Springs Prospecting project (attached as exhibit 10 (with internal <br />attachments)) states: <br />Prospecting was conducted as described in three Notices of Intent to Conduct Prospecting <br />Operations submitted to the Colorado Department of Natural Resources, Mined Land <br />Reclamation Board, dated August 23, 1977, November 10, 1978, and October 27, 1980 <br />(Attachment A). A total of 492 uranium exploration boreholes were drilled during this <br />period. <br />Mr. J.J. Faulhaber, of Alternative Energy, in an interoffice memo, dated May 28, 1985 <br />(Attachment D) summarized borehole abandonment procedures and standards for the <br />Project. Boreholes were abandoned with drilling mud consisting of varying viscosities <br />from the bottom of the hole to ten feet below the ground surface. Cement plugs were <br />installed from ten feet to the surface or two feet below the surface depending upon local <br />cultivation practices. <br />The borehole abandonment standards varied over the course of the Project, but the most <br />stringent standards applied to the 1980 drilling program.... <br />The boreholes were drilled into the stratigraphic horizon that contains the Laramie-Fox <br />Hills aquifer, a regional hydrogeologic unit that spans the base of the Laramie Formation <br />and the top of the Fox Hills Formation. In a letter to Mr. Kenneth Holmes (Mobil), dated <br />February 23, 1982 (Attachment E), Ms. Walker [Colorado Division of Mining] expressed <br />concerns over the use of drilling mud in an interval of an aquifer, and the potential for <br />contaminants in the Upper Laramie Formation to enter the Laramie-Fox Hills aquifer. <br />The interoffice memo referred to in this excerpt (exhibit 10, internal attachment D) also <br />refers to well abandonment procedures that were done in the 1970s, before Colorado legislation <br />passed in the early 1980s (House Bill 1195) that required more substantial protections in drill <br />hole abandonment procedures to protect groundwater. These documents refer to use of such <br />materials as "beet pulp" in the abandonment procedure in wells. <br />14