2014-06-13_ENFORCEMENT - C1981014 (2)

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COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 June 13, 2014 George Patterson Rich Munson Energy Fuels Coal Inc. P.O. Box 459 Florence, CO 81226 Re: Notice of Violation CV- 2013 -002 — Southfield Mine- Permit No. C- 1981 -014 Dear Sirs: Based upon the technical review provided below, the Division of Reclamation, Mining and Safety (DRMS) cannot terminate the Notice of Violation CV- 2013 -002. We understand that Energy Fuels Coal, Inc. (EFCI) will need additional time to address the ongoing matter. We therefore acknowledge that an extension of the current June 13, 2014 abatement deadline is necessary and is hereby generally granted. Please provide the appropriate documentation requesting such an extension at your earliest opportunity. Please include the date by which EFCI can abate the violation. Technical Review We have reviewed the letter dated March 14, 2014 from EFCI to DRMS regarding the Monitor Well MW -NW - Related Elevations. Our review of this additional information further clarifies and supports the concern that well MW -NW is likely not properly constructed as a groundwater monitoring well and will provide limited use as such. This monitoring point may be useful if the blockage is removed, so that a water level indicator could be lowered to the level of the mine workings and determine if mine inflow has reached this level of the mine. According to the available information, the well had a completion interval from 360' - 380', but there is no completion log to verify this assertion. It appears that the well was not constructed with a screen, gravel pack, and bentonite /cement sanitary seal which are required for a properly functioning well and accurate water level measurements (potentiometric head). Based on what we know now, the well is likely an intact steel casing down to the top or roof of the mine to an elevation of 5860.5 feet above msl. The blockage in the casing is at an elevation of 5879.7 feet, or 19.2 feet above the roof of the mine. To our knowledge the steel casing does not extend into the mine workings. The condition of the steel casing below the blockage has not been verified but is believed to be intact. The casing is dry above the blockage. The other existing monitoring wells at the site penetrate coal zones and the wells are constructed such that the perforated interval is in the coal zone. The coal zones are under confined conditions so the water in a 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http: / /mining.state.co.us John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director