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