2015-02-12_REVISION - C1981014

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 2/12/2015
• Doc Name: Adequacy Review
• From: DRMS
• To: Energy Fuels Coal, Inc
• Type & Sequence: TR43
• Email Name: LDS
• Email Name: DIH
• Media Type: D
• Archive: No

AN,COLORADO
Division of Reclamation,
Mining and Safety
Department of Natural Resources
1313 Sherman Street, Room 215
Denver, CO 80203
George V. Patterson
Energy Fuels Coal, Inc.
Southfield Mine
PO Box 459
Florence, CO 81226
February 12, 2015
Re: Southfield Mine (Permit No. C- 1981 -014)
Technical Revision No. 43, (TR43)
Adequacy Review
Dear Mr. Patterson,
The Colorado Division of Reclamation, Mining and Safety (the Division) has completed the
review of materials submitted by Energy Fuels Coal, Inc. (EFCI) for Technical Revision 43
(TR43). TR43 seeks to terminate all water monitoring at the Southfield mine.
At this time the Division is not able to approve TR43 and terminate water monitoring. The
various reasons for this are described in detail in the remainder of this letter.
The termination of water monitoring at a mine site is usually approved with final bond release,
although it is not without precedent for the Division to approve such a termination in advance of
the final bond release application. In either case, the application to terminate water monitoring
must satisfy the same criteria. Materials to be submitted by the operator for the Division's review
are discussed in a guideline document.' Part 1, section IV (A), item 5 of the guidance document is
summarized as follows:
The operator should provide a detailed analysis of the impacts to the quantity and quality of
surface water and groundwater.
The analysis should show that onsite impacts have been minimized and offsite impacts
prevented, and should include:
• an assessment of the available hydrologic data, relative to the impact projections
contained within the approved Probable Hydrologic Consequences (PHC) and the
applicable Cumulative Hydrologic Impact Assessment (CHIA); and
• an evaluation of any impact trends which may exist in the available data
With the TR43 application, EFCI submitted a cover letter and 5 attachments: (A) Proposed Public
Notice; (B) DRMS Hydrologic Review; (C) Historical Water Monitoring Data; (D) Map 12, Mine
Area Surface and Groundwater Hydrology; and (E) Exhibit 25, Hydrologic Monitoring Program
(additional introductory page). Attachment B, the "DRMS Hydrologic Review ", is a copy of an
interoffice memorandum written by the Division on June 3, 2013, with the subject: Groundwater
o CC310
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1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http: / /mining.state.co.us I
John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Directori,
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