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