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energy fuels coal, inc. <br />southfield mine - post office box 459 - florence. colorado 81226 - (719) 784.6395 <br />RECEIVED <br />January 19, 2015 JAN 2 0 2015 <br />Mr. Mike Boulay <br />Colorado Division of Reclamation. Mining & Safety Division of Reclamation, <br />1313 Sherman Street — Room 215 Mining & Safety <br />Denver. CO 80203 <br />RE Energy Fuels Coal, Inc. and DRMS meeting (01- 09 -15) regarding TR -43 and MW -NW Monitor <br />Well <br />Dear Mike Boulay: <br />My assessment of the January 9. 2015 meeting at the DRMS and some previous related correspondence <br />is that some features effecting the Southfield hydrology has been overlooked or perhaps disregarded. <br />Underground mining rule -of -thumb is that rubblization of subsidence zones typically reaches a height of 9 <br />to 13 times the height of the mine workings 10 times (10X) of the mine workings height is a typical <br />calculation. Given that the mine working height in the 1st North Mine Section (MW -NW) and 1 -1/2 North <br />Section (adjacent to MW -NW) is six vertical feet, the predicted height of rubble in pillared areas would be <br />60 vertical feet. The majority of Southfield was pillared, therefore much rubblization 60 feet or more above <br />the mine roof Is expected <br />The 1 -112 North mine section is adjacent to MW -NW. As is explained in previous reviews. 1st North, 1 -1/2 <br />North and 2 North sections are all open to water flow through the permeable gob in these sections. That <br />was witnessed by the mining crews The partial obstruction in MW -NW is located in the lower portion of <br />the rubble zone (in the lower 20 feet of the 60 -foot high rubble zone). We also know from the two water <br />tests that it is in communication with the rubble zone in and above the mine workings. David Berry 's 6- <br />13-14 letter. and Mike Boulay's comments at the January 9, 2015 meeting. show the DRMS agrees that <br />water will move freely through the permeable rubblized area Therefore, GIVEN THAT THE PARTIAL <br />OBSTRUCTION IN MW -NW IS WITHIN THE RUBBLE ZONE, WATER WILL ENTER THE WELL <br />CASING, either at the point of the obstruction or below at the bottom of the pipe at the mine roof level, <br />AND SEEK THE SAME LEVEL AS WATER IN THE RUBBLE ZONE Thus. MW -NW is functional for <br />monitoring if and when groundwater raises above the partial obstruction. <br />Attached is a cross sectional sketch of the bottom portion of MW -NW to describe this feature This <br />explanation and the sketch should justify terminating the NOV and support approval of TR -43. <br />If you have any questions or comments, please contact me. <br />Sincerely, <br />e V Pa rson <br />Energy Fuels Coal, inc. <br />Enclosure Sketch. X- section view of MW -NW rubble zone <br />Cc Rob Zuber <br />