2013-09-03_REVISION - C1981014 (2)

Home Browse Search

Snail mailing this citizen complaint also. TO: Janet Binns, Dan Hernandez, Kent Gorham, Robert Zuber FROM K2T, LLC and South Central LLC July 24, 2012 This is a Citizen Complaint regarding lack of adequate well testing to ensure water quality and quantity standards on a 400 acre property that has been a coal mine and has a 35 acre coal tailings pile. History- Southfield Mine has been mined by Energy Fuels since 1985. Originally Dorchester Coal drilled Wells 10, 16, 18, and 23 into different coal seams. At the 2003 Bond release hearing before the Colorado Division of Mining, Geology and Safety, the property owners expressed concern about the water quality not meeting quality standards and lack of wells from which to take samples. The wells tested high in iron, manganese, and sulfites. (Attachment 1). Well 10 was mined through. Well 16 was dry starting in 2002, but later was tested in 2004 and 2005 and has been dry since then. Only Well 23 at 157 feet has been consistently tested. When Well 23 was tested in 2008, EF was sited for confusion regarding sampling constituents. EF was asked "to ensure that all future sampling is in exact accordance with the approved plan ". Also the 2009 Annual Hydrology plan was not filed by the due date and EF was cited. The latest example of lack of water testing by EF is when Janet Binns and Kent Gorham found the cable and monitor broken and in the bottom of the well MW -NW. The well has been reported dry by EF since 2003 -2011. How long had it been broken and no effort to repair it has been made by EF? In April, 2012 the inspectors found water at 320 and the well was not dry and could have been tested this spring. Now EF is reporting the well again dry on May 4 and May 29, when George Patterson lowered the Olympic Well Probe several times to depth of 345 and 360 feet. In the 2008 Annual Hydrology Report Review's next to last paragraph, Kent Gorham wrote "Until water is measured in MW -NW, no conclusion regarding ground water quality can be made." According to Janet Binns in her May 15, 2012 Inspection Report, "Rehabilitation of MW -NW is necessary to meet the approved water monitoring plan." How is the Division of Reclamation planning on directing Energy Fuels to do this? Since the City of Florence water pipe that comes across our property is untreated, there is no way that we will ever be able to connect to it for potable water. Therefore, we will have to have a well(s) that can pass the Secondary Drinking Water Standards before Energy Fuels leaves the site. Our goal is that adjacent domestic wells have drinkable water according to the Federal Clean Water Act and Senate Bill 89- 181 - Colorado Water Quality Control Act. Heavy metals are naturally present in areas where there is coal. The only consistent testing has been of Well 23 which is only 140 feet deep. Most domestic wells are 350 feet and well water at this depth needs to be tested. The semi - annual water testing presently shows many samples that are testing higher than the Maximum Contaminant Level (MCL) including sulfates, iron, manganese, solids, and sodium and in recent years, the ph has been at the maximum suggested level (Attachment 2). Well 10 showed historically high numbers in iron and manganese before it was mined through. Historical data from 1979 -2010 for Well 23 (Hydrology Reports MW -23- Water Quality Data) shows iron was extremely high. It was 0.86 when the Colorado Department of Public Health and Environment: Drinking Water Section on Chemical and Radiological Statistics list the maximum should be 0.3. Sodium's suggested level is 20.0 by their standards and Well 23's level was 356 in May 2008, 299 in December 2008, 326 in June 2009, 180 in December 2009, 205 in June 2010 and 231 in December 2010. Roger Zuber notes in the 2010 Hydrology Review. "Some elevated levels must be scrutinized in the future for continuing trends: Calcium and Magnesium in Well 23 and Nitrogen in Well 23." According to our research, there are several other concerns: Manganese, Sodium, pH, Iron, and solids. Several of these are very harmful especially to infants and small children including neurological problems. More data can be found on Attachment 2. It seems that water quality within one mile of a coal operation is to be monitored according to Senate Bill 89 -181 for potential groundwater contamination within one mile of our mine or of the mine tailings. We ask that an environmental specialist from the Division of Mining, Reclamation and Safety ensure that the domestic wells surrounding the coal properties are not contaminated from Energy Fuels coal mining operations. It is possible that Energy Fuels might need to drill additional wells for testing since there have really only been two wells reporting for about seven years.