2015-04-23_REVISION - C1981014 (2)

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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 April 23, 2015 Re: Southfield Mine (Permit No. C- 1981 -014) Technical Revision No. 43, (TR43) Second Adequacy Review Dear Mr. Patterson, The response to the initial adequacy review for Technical Revision 43 (TR43) was a letter from EFCI dated March 16, 2015, received by the Division on March 24, 2015, which was submitted with three appendices: (A) Evaluation of Probable Hydrologic Consequences and Water Data Trends, by Weaver Engineering Services, which will be referred to as the March 2015 Weaver Analysis; (B) Bishop - Brogden and Associates Adequacy Review Responses, which will be referred to as the March 2015 BBA letter; and (C) Table 11 — Well permits within 1 mile of the Southfield permit boundaries, and Corley new well No. 296198 information. Summary: At this time the Division is not able to approve TR43 and terminate water monitoring. Through the review process it has become clear that the outstanding adequacy issues cannot be addressed prior to the resolution of NOV CV- 2013 -002. The Division suggests that EFCI either withdraw TR43, or request an extension to the Proposed Decision Due Date for TR43 in order to allow time for the abatement of the NOV. In this, the second adequacy review, pertinent sections of EFCI's March 16 response letter are reproduced, together with any text from the initial adequacy review letter to which they refer. For the sake of clarity, other text is not included. All quoted text is inset, and text from EFCI is italicized. As previously, items which require, or required, a response are in bold. 1) Groundwater a) Groundwater Monitoring DRMS: 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, 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 NOV CV- 2013 -002). 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http: / /mining.state.co.us John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director pF Cpl0 _\ �y xi 1876x/