2013-09-03_REVISION - C1981014 (4)

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test used five gallons of water to test SF87 -07. We believe that five gallons is significantly different than the 1,500 gallons that EFCI used to test the MW -NW monitoring well. Concerning Drill Hole SF87 -09, EFCI previously informed the Division that SF87 -09 had been plugged approximately midway in the casing during drilling operations and a screen was installed at that point. The Corley Company is aware of this because, at your request, EFCI previously had sent you the drill logs details for SF87 -07, SF87 -09 and several other drill holes at Southfield. Although the BBA report does not specify Newlin Creek per se', the narration subtitled "Background" is comprehensive in addressing the Vermejo Formation that encompasses the Southfield mine area. The report states the strata of the formation act as aquacludes restricting vertical ground water movement and the low permeability and the lenticular nature of the formation restricts horizontal groundwater movement. Given the findings of the geohydrologic studies done on Southfield that specify the tight strata formations restricting groundwater movement, to assume that the Southfield mine workings and adjacent abandoned mine voids have all refilled with groundwater in a matter of a few years rather than the 200 to 300 years predicted by specialized consultants seems highly unlikely. The Boulay Report addresses Newlin Creek and also is in agreement with BBA's geohydrologic report that the strata encompassing the Southfield mine are of low permeability and restrictive to vertical and horizontal groundwater movement. Concerning surface water flow of Newlin Creek, the Boulay Report states that the deep alluvium comprising the Newlin Creek stream bed is from 5 to 100 feet in depth. The EFCI permit also documents the deep alluvium which is described in the pre- mining baseline data information of the permit and predicts an acceptable range of subsidence for the Southfield operations. Further, the drill logs of several drill holes near Newlin Creek document the alluvium as ranging from 50 to 100 ft deep consisting of sand, gravel and boulders. We retained the services of BBA to help us better analyze the overall monitoring program for groundwater and particularly how MW -NW fits into that program. Prior to their involvement EFCI had requested that the monitoring point for MW -NW be changed to a level at or just above the level of the obstruction. However, the BBA work which followed the extensive review of the program by the Division that has been summarized in the Boulay Report led to the conclusion that MW -NW is not a necessary component of a groundwater program that will provide reliable data to evaluate the impacts, if any, on groundwater in the area. Our request as set out in TR 40 is based on BBA's conclusions and recommendations which we believe are consistent with the Divisions' findings. Sincerely, George V Patterson Energy Fuels