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DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />March 28, 2014 <br />STATE OF COLORADO <br />COLORADO <br />ID IV I S I O N O F <br />RECLAMATION <br />MINING <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Mr. George Patterson <br />Loretta E. Pineda <br />Energy Fuels Coal, Inc. Director <br />P.O. Box 459 <br />Florence, CO 81226 <br />RE: Southfield Mine, Permit C- 1981 -014, Adequacy Issues, Permit Renewal Number 6 (RN -06) <br />Dear Mr. Patterson: <br />The Division of Reclamation, Mining and Safety (Division) has received your application for renewal of EFCI's <br />Southfield Mine permit. The application was received by the Division on January 21, 2014, and found complete on <br />January 30, 2014. Thank you for your timely submittal of the renewal application. <br />Pursuant to Rule 2.08.5(3)(f) an application for renewal must be received by the Division no later than 180 days before <br />the expiration of the existing permit in order for the operator to maintain the right of successive renewal. In addition, an <br />application for renewal must be found complete by the Division no later than 180 days prior to permit expiration in order <br />for the operator to maintain the right of successive renewal (pursuant to Rule 2.08.5(2)(a)). EFCI's permit expires on July <br />30, 2014. Based on the expiration date, the Division must have received and found complete EFCI's application no later <br />than January 31, 2014. Since the Division received and found complete the application for renewal prior to this date, <br />EFCI retains the right of successive renewal for Coal Mining Permit Number C- 1981 -014. <br />Based on the Division's review of the materials submitted with the application for RN -06 and based on a review of the <br />approved Permit, the Division has the following adequacy comments, which are divided into those related to issues <br />carried over from the last midterm review (MT -06) and additional issues. A second adequacy letter focusing on <br />groundwater issues in the Permit Application Package (PAP) will follow this letter in the near future. <br />Some of the items below refer to needed edits in the PAP. Some of these issues can be addressed by adding introductory <br />paragraphs to PAP sections. These paragraphs should explain to the reader that the majority of information in the section <br />was written many years ago and may be outdated, but it is retained to document the history of the site. These paragraphs <br />should also describe the current status of the mine and loadout. For example, the PAP discussion of ponds pre -dates <br />reclamation of some of these structures; an introductory paragraph could alert the reader of this fact. <br />Issues Related to MT -06 <br />The following issues are related to the most recent midterm review of your permit by the Division. Many of the midterm <br />items have been resolved, and others are pending actions by EFCI or the Division. The following list includes particular <br />items that the Division has chosen to incorporate into this renewal review. <br />1. MT -06 item Number 10: Regarding the Corley Company well, the corrected location of the well overlies Southfield <br />workings, and the potential impact of subsidence on this well needs to be analyzed by EFCI. If necessary, EFCI will <br />need to develop a plan to mitigate damage to the well caused by subsidence. The PAP will need to be updated as <br />noted below. <br />2. MT -06 item Number 11: MR -62 was submitted by EFCI to address this issue. A decision regarding this revision and <br />a judgment regarding the resolution of this midterm issue are pending. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines <br />