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RECEIVED <br />MAR 2 4 2015 <br />DIVISION OF RECLAMATION <br />Rob Zuber — Reclamation Specialist LENIN, G A ) WETI <br />Division of Reclamation Mining & Safety March 16, 2015 <br />1313 Sherman Street - Room 215 <br />Denver, CO 80203 <br />Re: Energy Fuels Coal, Inc. (EFCI) - Southfield Mine (Permit No. C- 1981 -014) <br />Adequacy Review Response - Technical Revision No. 43, (TR43) <br />Dear Rob Zuber: <br />This letter and attachments is Energy Fuels Coal, Inc. (EFCI) response to the Division's <br />Adequacy Review letter dated February 12, 2015 concerning Technical Revision No. 43 (TR- <br />43). EFCI's response is written in the same format and chronological order as the Division's <br />February 12, 2015 Adequacy Review. EFCI's responses are written in Blue Italic text in a <br />question/comment — answer format. <br />The copy of the Division's February 12, 2015 Adequacy Review and EFCI' response follows: <br />The Colorado Division of Reclamation, Mining and Safety (the Division) has completed the <br />review of materials submitted by Energy Fuels Coal, Inc. (EFCI) for Technical Revision 43 <br />(TR43). TR43 seeks to terminate all water monitoring at the Southfield mine. <br />At this time the Division is not able to approve TR43 and terminate water monitoring. The <br />various reasons for this are described in detail in the remainder of this letter. <br />The termination of water monitoring at a mine site is usually approved with final bond release, <br />although it is not without precedent for the Division to approve such a termination in advance of <br />the final bond release application. <br />RESPONSE_: Records show that the Division's (DRMS) previous practice concerning the Kerr /Marr mine in Jackson <br />County, Colorado, terminated the Kerr water monitoring program (Technical Revision No. 23 (TR -23)) at the mine site <br />effective October 15, 2007. The Phase 3 Final Bond Release for the Kerr mine site's remaining liability areas and the <br />Loadout site was approved effective July 29, 2013. Given the previous practice of the DRMS concerning the Kerr /Marr mine <br />wherein the water monitoring program was terminated long before the Final Bond Release (5+ years) and considering that <br />the Southfield mine has completed Year 10 of the Ten Year Reclamation Liability Period, EFCI reiterates that termination of <br />the surface and groundwater monitoring program at the Southfield mine is timely and just. <br />In either case, the application to terminate water monitoring must satisfy the same criteria. Materials <br />to be submitted by the operator for the Division's review are discussed in a guideline document.' Part <br />1, section N (A), item 5 of the guidance document is summarized as follows: <br />