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George V. Patterson, Energy Fuels Coal, Inc. Page 6 February 12, 2015 a) Groundwater Monitoring The approved groundwater monitoring plan at the Southfield Mine is designed to monitor only water within the interval disturbed by the mine, which is reasonable given the preceding discussion of the hydrogeologic context at the site. No groundwater points of compliance have been established at the Southfield Mine. Firstly, it was not determined that there was potential for the mining operation to negatively impact the quality of groundwater for which quality standards had been established by the Water Quality Control Commission. Secondly, given the preceding discussion regarding the isolation of potential groundwater impacts to the coal seam and flooded mine workings, combined with the fact that the in -situ quality of this water is known to be degraded; points of compliance were deemed unnecessary. This matter is fully discussed in the June 2013 Memo. The approved water monitoring program is described in Exhibit 25 of the PAP. Two parts of the program relate to groundwater. The first of these is semi - annual sampling of four monitoring sites (MW 16, MW23, MW65 and MWNW, shown in figure 2) to determine the water level and the concentrations of a suite of suggested water quality parameters. The operator has been out of compliance with this part of the monitoring plan for several years since MWN W is blocked (this is the subject of the outstanding Notice of Violation CV- 2013 -002). The second part of the monitoring plan relating to groundwater was discontinued in December, 2000, with mine closure. It required that points of inflow within the active workings be surveyed semi - annually to estimate quantity, measure field parameters of water quality (pH, conductivity and temperature), locate the inflows on a map, and document the data in the Annual Hydrology Report (AHR). The operator estimated the quantity of water flowing into the mine based on observations made at inflow and seep locations within the open part of the mine. Prior to 1994 the metered discharge at the surface from the North Dewatering Well (now, MWN W) was factored in to the estimate. After 1994 water was pumped to low spots within the mine workings, rather than being discharged; it is understood that this pumping data was used in the estimate also. The estimated mine inflows are summarized in Table 1. Table 1: Summary of Estimated Mine Inflows (data copied from Annual Hydrology Reports) Monitoring Year Estimated Inflow (Acre -feet) 2000 10.3* 1999 15.2** 1998 9.7** 1996 -1997 39.6 1995 -1996 [Unable to locate AHR] 1994 -95 49.9 1985 -1994 64.1 avg. (per 1994 AHR) *The 1North/2 North area was inaccessible during 2000. It should be noted that during 1997 this area made up 86% of the reported mine inflow * *No inflow was observed in the 1North/2 North area