2013-08-22_REVISION - C1981014 (3)

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Received by DRMS 8/19/2013 Objection to TR40 by EFCI requesting to no longer monitor MWNW Linda Saunders <saunders615 @live.com> Sun, Aug 18, 2013 at 2:43 PM To: "janet.binns @state.co.us" <janet.binns @state.co.us >, "daniel.hernandez @ state.co.us" <daniel.hernandez @ state.co.us>, "mike.boulay @state.co.us" <mike.boulay @state.co.us >, "loretta.pineda @state.co.us" <loretta.pineda @state.co.us >, Tena Gallagher <tena @aol.com >, "paulacoulter @comcast.net" <paulacoulter @comcast.net >, "tedcoulter @yahoo.com" <tedcoulter @yahoo.com> To: Division of Reclamation, Mining, and Safety Staff From: K2T LLC, Linda Saunders, property owner Date: August 18, 2013 RE: Response to TR 40- Energy Fuels Coal Inc request to no longer monitor MWNW Energy Fuels Coal Inc (EFCI) should not be allowed to remove monitoring well MWNW from their approved water monitoring program. EFCI has requested to no longer monitor MWNW in the Southfield Permit area on our property. This monitoring well intercepts the Southfield Mine Workings in the Red Arrow and Jack O' Lantem Coal seam. EFCI needs to continue monitoring MWNW as part of their Hydrologic Monitoring Plan according to regulations 4.05.13(1)(a), 4 .05.13(1)(c),4.05.13(1)(e)e(i), 4.05.13(3)(a) and 4.05.13(3)(b). To no longer monitor MWNW would be non - compliance with these regulations. The mining company has damaged MWNW by not removing a piece of wood 2 "X4 "X8" that is lodged in the pipe 19 -20 inches above the mine void that they were to be monitoring. This was discovered by the DMRS staff when they put a camera into the pipe and discovered the piece of wood and EFCI's monitoring equipment. MWNW has always been reported dry by EFCI. This piece of wood needs to be removed so that EFCI can continue monitoring MWNW until their final bond release and the property owners could monitor MWNW after EFCI's final bond release. Drill hole SF 87 -07 near MWNW had water in it recently. So it is possible that the mine could fill up before the hydrologists projections in Scenerio 2 and 3. If Newlin Creek is going underground as we think it is on our property, MWNW would help determine if this is the case. The property owner has contacted the Colorado Division of Water Resources to determine if MWNW has ever been permitted by them as a monitoring well in accordance with Rule 2.03.10. This has been turned over to Dale Baker, field investigator for the Colorado Division of Water Resources. I have corresponded with Steve Witte and Janet Garoutte. A copy of the email's was posted on the DRMC's website. The only permit that EFCI requested (12508 -AD 7/22/1991 was denied. If the Division of Reclamation, Mining and Safety decides that EFCI no longer needs to monitor MWNW, I would like to have this issue heard by the Board.