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2013-09-03_REVISION - C1981014 (2)
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2013-09-03_REVISION - C1981014 (2)
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Entry Properties
Last modified
8/24/2016 5:24:40 PM
Creation date
9/4/2013 8:20:28 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
9/3/2013
Doc Name
Tena Gallagher Objection to TR40 (Emailed)
From
Tena Gallagher
To
DRMS
Type & Sequence
TR40
Email Name
JHB
DIH
Media Type
D
Archive
No
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Snail mailing this citizen complaint also. <br />TO: Janet Binns, Dan Hernandez, Kent Gorham, Robert Zuber <br />FROM K2T, LLC and South Central LLC <br />July 24, 2012 <br />This is a Citizen Complaint regarding lack of adequate well testing to ensure water quality and quantity standards on a <br />400 acre property that has been a coal mine and has a 35 acre coal tailings pile. <br />History- Southfield Mine has been mined by Energy Fuels since 1985. Originally Dorchester Coal drilled Wells 10, 16, 18, <br />and 23 into different coal seams. At the 2003 Bond release hearing before the Colorado Division of Mining, Geology and <br />Safety, the property owners expressed concern about the water quality not meeting quality standards and lack of wells <br />from which to take samples. The wells tested high in iron, manganese, and sulfites. (Attachment 1). Well 10 was mined <br />through. Well 16 was dry starting in 2002, but later was tested in 2004 and 2005 and has been dry since then. Only Well <br />23 at 157 feet has been consistently tested. When Well 23 was tested in 2008, EF was sited for confusion regarding <br />sampling constituents. EF was asked "to ensure that all future sampling is in exact accordance with the approved plan ". <br />Also the 2009 Annual Hydrology plan was not filed by the due date and EF was cited. <br />The latest example of lack of water testing by EF is when Janet Binns and Kent Gorham found the cable and monitor <br />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 <br />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 <br />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 <br />George Patterson lowered the Olympic Well Probe several times to depth of 345 and 360 feet. In the 2008 Annual <br />Hydrology Report Review's next to last paragraph, Kent Gorham wrote "Until water is measured in MW -NW, no <br />conclusion regarding ground water quality can be made." According to Janet Binns in her May 15, 2012 Inspection <br />Report, "Rehabilitation of MW -NW is necessary to meet the approved water monitoring plan." How is the Division <br />of Reclamation planning on directing Energy Fuels to do this? Since the City of Florence water pipe that comes across our <br />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 <br />have a well(s) that can pass the Secondary Drinking Water Standards before Energy Fuels leaves the site. <br />Our goal is that adjacent domestic wells have drinkable water according to the Federal Clean Water Act and Senate Bill <br />89- 181 - Colorado Water Quality Control Act. Heavy metals are naturally present in areas where there is coal. The only <br />consistent testing has been of Well 23 which is only 140 feet deep. Most domestic wells are 350 feet and well water at this <br />depth needs to be tested. The semi - annual water testing presently shows many samples that are testing higher than the <br />Maximum Contaminant Level (MCL) including sulfates, iron, manganese, solids, and sodium and in recent years, the ph <br />has been at the maximum suggested level (Attachment 2). Well 10 showed historically high numbers in iron and <br />manganese before it was mined through. <br />Historical data from 1979 -2010 for Well 23 (Hydrology Reports MW -23- Water Quality Data) shows iron was extremely <br />high. It was 0.86 when the Colorado Department of Public Health and Environment: Drinking Water Section on Chemical <br />and Radiological Statistics list the maximum should be 0.3. Sodium's suggested level is 20.0 by their standards and Well <br />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 <br />231 in December 2010. Roger Zuber notes in the 2010 Hydrology Review. "Some elevated levels must be scrutinized in <br />the future for continuing trends: Calcium and Magnesium in Well 23 and Nitrogen in Well 23." According to our research, <br />there are several other concerns: Manganese, Sodium, pH, Iron, and solids. Several of these are very harmful especially <br />to infants and small children including neurological problems. More data can be found on Attachment 2. <br />It seems that water quality within one mile of a coal operation is to be monitored according to Senate Bill 89 -181 for <br />potential groundwater contamination within one mile of our mine or of the mine tailings. We ask that an environmental <br />specialist from the Division of Mining, Reclamation and Safety ensure that the domestic wells surrounding the coal <br />properties are not contaminated from Energy Fuels coal mining operations. It is possible that Energy Fuels might need to <br />drill additional wells for testing since there have really only been two wells reporting for about seven years. <br />
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