2013-08-21_REVISION - C1981014 - Laserfiche WebLink

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August 21, 2013 Ms. Janet H. Binns Division of Reclamation, Mining and Safety 1313 Sherman St., Rm. 215 Denver CO 80203 Dear Ms. Binns: We received your letter regarding Energy Fuels Coal, Inc. (EFCI) application for Technical Revision No. 40. We have the following concerns and wish to object to the applicant's proposal to remove MWNW from the approved monitoring program. On May 16, 2013, we sent DRMS and EFCI a report of our observations and survey measurements concerning surface and ground water of the Southfield Mine area. We will not restate all of those specifics here, but we do note that most of those issues we raised have not been addressed by the July 23, 2013, Bishop and Brogden Assoc. (BBA) hydrology report, which report was summarized by EFCI and posted on the DRMS web site. That summary focuses on MW23 and MW65 as being upgradient and downgradient respectively with emphasis on the reduced water levels in both wells when the Southfield Mine dewatering was started. The BBA conclusion is that both monitoring wells are therefore hydrogeologically connected to the Southfield Mine workings. We would agree that MW65 which was drilled thru the Black Diamond Mine void is interconnected with the Southfield Mine. The next conclusion of BBA is that the water levels in MW23 and MW65 have not recovered 15 years after Southfield Mine dewatering was terminated, and BBA uses this as evidence that the Southfield Mine is not quickly filling. We would like to again make the point that the water elevation in MW65 is now and has been for many years the same elevation as several other open wells that penetrate old mine workings and an open well that penetrates Southfield Mine, and it is also equal to the elevation of the surface discharge of water into Second Alkali Creek. The elevation of that discharge location is the limiting elevation for the water level in MW65 which is connected to the Southfield Mine. The other specific open wells all having the same water level elevations are SF- 87 -09, SF- 87 -07, and the Corley Mine Well which was used by EFCI for its water source. At a previous field inspection Janet Binns informed us that EFCI had told her that SF -87 -07 had been partially plugged. Unless EFCI has additional information, the Dec. 15,1987, drill log does not report any plugging. This exploratory drill hole has been left open for 26 years. Southfield Mine mined thru this drill hole in the 2 North Panel and removed the pillars at an unknown date. The well cap and PVC casing are defective which allow surface water and sediment to enter this well. The casing had no screens or other perforations at any depth. Therefore, the only known openings into the casing are at the top and the bottom ends. A small amount of water was added to this well in a similar water test as EFCI used on MWNW in order to demonstrate that this well is open to the Southfield Mine workings. The static water level rose and then returned to the pre -test level. This open exploratory drill hole is only about 700