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George V. Patterson, Energy Fuels Coal, Inc. <br />Page 16 <br />February 12, 2015 <br />The second part of the surface water monitoring program is the sampling of sediment pond <br />discharges for water quality and flow at four locations: Pond 4 (discharge point 002 for the CDPS <br />permit for the mine site), Pond 5 (discharge point 004 for the CDPS permit for the mine site), <br />reclaimed Pond L -1 (discharge point 001 for the CDPS permit for the loadout), and reclaimed Pond <br />L -2 (discharge point 002 for the CDPS permit for the loadout). Discharge is to be sampled weekly <br />for flow and selected water quality parameters, and monthly for a full suite of water quality <br />parameters, during periods of active discharge. For several years, no flow has been recorded at any <br />of these CDPS outfalls. As noted below, the Division has requested (in the context of pending TRs) <br />that EFCI grab samples of water from Pond 4 and Pond 5 and have these samples analyzed by a <br />reputable laboratory. <br />Please continue to follow the approved water monitoring program, and to attempt to monitor <br />the creeks during times of high flow. <br />b) Surface Water Rights <br />Details of surface water rights in the area of the Southfield Mine are described in Table 15 of the <br />PAP. The City of Florence owns water rights to the entire flow of Newlin Creek, and exercises this <br />right through a diversion upstream of the permit area (page 2.04.7 -23). From the diversion down to <br />the confluence with Hardscrabble Creek, Newlin Creek is an ephemeral stream, flowing only in <br />response to relatively large snowmelt or rain events. <br />The two other creeks, Magpie and Second Alkali, are also ephemeral and have no water rights <br />associated with them per Table 15. However, these creeks are tributary to Hardscrabble Creek, and <br />there are several water rights listed for this source. <br />Per the information in Table 15, there is a legal possibility that the rights of downstream water users <br />could be impacted by the Southfield Mine. The pertinent issue is the physical impacts of the mine <br />on the surface water in the three creeks, as described below. <br />c) Impacts to Surface Water Quantity <br />The data and analysis provided do not allow a judgment to be made as to the impacts of the <br />Southfield Mine on the quantity of water flowing in the three potentially affected streams. <br />i) Please provide the full data set of surface water flow measurements from MCI, MC2, <br />NCI, NC2 and SAL (EFCI included data from 2000 to 2013 in the TR43 submittal, but <br />the entire dataset, including data from AHRs prior to 2000, should be listed for <br />consideration) <br />ii) Please analyze all of the available data for long term trends in surface water flows in <br />Magpie Creek, Newlin Creek and Second Alkali Creek. <br />