2015-04-23_REVISION - C1981014 (2)

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George V. Patterson, Energy Fuels Coal, Inc. Page 6 April 23, 2015 2013 Memo (page 13), wherein it states `Additional monitoring of the coal zone is not warranted. - - - since groundwater is already known to be of degraded quality and unlikely that it would be put to beneficial use, this would provide little additional information - - - ". DRMS: ii) Please clarify the lowest elevation that could be measured if MWNW were clear, and whether or not this is the floor of the mine, (5855' was the elevation discussed in TR35 adequacy correspondence and given on page 2.05.6 -53 of the PAP; 5860.5' was used in the 2013 Summary Report by BBA) EFCL- As previously stated, the elevation of the floor of the mine workings is 5855 feet. The mine workings were 5.5 feet in height in the vicinity ofMW -NW, the referenced elevation of 5860.5 feet stated in the BBA 2013 Summary Report is the elevation of the roof of the workings where the steel casing was cut off during mining operations. DRMS: iii) Please provide a discussion of well MW16 explaining the fact that the recorded water level dropped below 120' below ground surface (bgs) numerous times between 1979 and 2000, but that since 2000 the well has often been reported as dry with the depth to water indicated as 110' bgs (according to Exhibit 25, the depth of MW16 is 136' and the screened interval is from 106' -136') EFCI: Regarding MW -16 although it is uncertain as to why water levels fluctuated in MW- 16 during 1979 -2000, potential water sources for MW -16 are the abandoned Peacock Mine and the abandoned Pine Gulch Mine, both being in the Red Arrow seam and situated up- dip from MW -16. Both mines are located at the outcrop and are recharged by precipitation. Given that the flooded Peacock Mine in particular, flowed into the Southfield Main Entries (Peacock Inflow 2), and that the Peacock is recharged by precipitation, it is conceivable that static water pressures in the abandoned mines (draining /recharging) were influencing the water levels in MW -16. The Division's statement that MW -16 was "often reported as dry at 110 ft with depth to water indicated as 110 ft" is contradictory. Various AHR's reported "mud" at 110 ft bgs which does not imply that that was the water level, i.e. the well had no water at 110 ft as reported in the respective AHR's. More importantly, the "'average' water level in MW -16 during the 1979 -2000 time period was 104.1 ft bgs approximately 2 ft above the screened interval of the well. Concerning MW -16 being reported as dry, the above referenced abandoned mines are located parallel to the Southfield Moose Panel and the Pine Gulch Panel 113 workings and being up -dip from MW -16, it is conceivable that the workings influenced water levels in MW -16. Further, as is referenced in the Division's February 12, 2015 Adequacy Review letter, (National Drought Mitigation Center (http: / /droughtmonitor. unl. edu)) the region has been in drought conditions for several years during which MW -16 has been dry. Nonetheless, according to well completion data, 4 vertical feet of the screened interval is available to accept water if it was present.