2015-04-02_REVISION - C1981014 (2)

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energy fuels coal, inc. southfield mine. po box 459. florence, colorado . 81212 March 26, 2015 Mr. Rob Zuber — Reclamation Specialist Colorado Division of Reclamation Mining & Safety 1313 Sherman St — Room 215 Denver, CO 80203 RECEIVED WR 0 2 2015 Division of Reclamation, Mining & Safety RE: Technical Revision No.42 (TR -42) Adequacy Review - EFCI Responses Energy Fuels Coal, Inc. (EFCI) — Permit No. C -81 -014 — Southfield Mine Dear Rob Zuber: This is in response to your Adequacy Review letter dated October 21, 2014 concerning Technical Revision No. 42 (TR -42) regarding the request to leave Southfield's Pond No. 4 as a permanent structure as per the request of the landowners, the Vento group. EFCI's responses are in the same numerical format as that of your October 21, 2014 letter. Item 1: The DRMS requires that EFCI obtains water analysis of Pond 4 by means of grab samples from the pond. Grab samples were obtained, analyzed and reviewed. Parameters analyzed were those recommended by the DRMS in your letter, "The Basic Standards and Methodologies for Surface Water" (Water Quality Control Commission). Tables 2 and 3 of the Standards outlines the parameters for agriculture. A copy of Table 2 and Table 3 with their respective explanation pages are attached in APPENDIX "A" included with this submittal for your ease of review. The water analysis for Pond 4, analyzed by ACZ Laboratories in Steamboat Springs, Colorado, are all found to be in compliance with the required parameters. A table, "Pond No. 4 and Pond No. 5 — Pond Water Grab Sample Analysis ", has been composed and is included in APPENDIX `B" enclosed with this submittal. Item 2: Item 2 references a letter from the Division of Water Resources (DWR) dated October 17, 2014, under the signature of Heidi Frey which stated concerns of retaining water in Pond 4 on a permanent basis. At that time, EFCI had not yet applied for a change of status for the pond to that of a livestock water tank, "Stock Water Tank ". Subsequently, the DWR has approved the permit for a Stock Water Tank for Pond 4. A copy of the permit is located in APPENDIX "C" included with this submittal. The DWR also included a copy of the respective Statute of regulations for Stock Water Tanks which approves the retention of water for use for livestock watering and wildlife habitat. If you have questions or require further information, please contact me.