2015-04-23_REVISION - C1981014 (2)

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George V. Patterson, Energy Fuels Coal, Inc. Page 2 April 23, 2015 EFCL MW -NW is NOT blocked. Two water tests, April 2012 and April 2014, proved that MW -NW is an open conduit to the Southfield mine workings allowing a water flow rate of more than 100gallons of water per minute (100 GPM) to flow down through the well. The DRMS has previously concurred with this evaluation There is no suggestion that the blockage of MWNW is a water tight seal, merely that the hole is blocked to the extent that it cannot be monitored below 5879.7', which is 19.2' above the bottom of the well casing and 247 above the floor of the mine at that point (per the March 2015 BBA letter) due to a "partial well obstruction ". DRMS: 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. EFCI Concerning the inflow table listed [below] and the footnote regarding 1997, the monitoring /reporting period (1996 -97) was extended to an 18 months duration via Minor Revision No. 34 (MR -34). The extension was due to the mine being idle because of the temporary lack of a coal sales contract. There are several apparent gaps in the data record, including from June 1986 to May 1988, and from July 1995 to June 1996, which coincided with a period where the operator was not able to sell coal. Does EFCI have records available for either of these periods? b) Groundwater Rights DRMS: Please update table 11 of the PAP. If any wells have been damaged please describe the extent to which operations at the Southfield Mine impacted the well and any measures EFCI have taken to mitigate the impact. If replacement wells have been drilled, please include relevant information about them. EFCI: Table 11 has been updated and is included in APPENDIX "C" with this submittal. Only one water well is known to have been impacted by Southfield mining. Although uncertain if the Corley Company Well (No. 119459) went dry due to mining subsidence, in good faith and in responding to the landowner's request, a new well was drilled for the Corley Company during December, 2014. Information on the new well, Permit No. 296198, is included in APPENDIX "C ". Another well (Thompson Well No. 22948) is listed in the PAP baseline data as having the