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energy fuels coal, inc. <br />southfield mine post office box 459 • florence, colorado 81226 • (719) 784-6395 <br />RECEpVr-'-) <br />May 18, 2015 <br />MAY 20 ��15 <br />Mr. Rob Zuber — Reclamation Specialist <br />Colorado Division of Reclamation Mining & Safety Division of <br />1313 Sherman St — Room 215 Mining & Safety <br />Denver, CO 80203 <br />RE: Technical Revision No. 46 (TR -46) - Relocation of MW -NW Monitor Well <br />Energy Fuels Coal, Inc. (EFCI) — Southfield Mine - Permit No. C-81-014 <br />Dear Rob Zuber: <br />This submittal addresses the requirements for abatement of the Southfield mine violation NOV <br />CV -2013-002. This submittal is also in response to the Division's Adequacy Review letter dated February <br />12, 2015 concerning Technical Revision No.43 (TR -43) which requests approval for termination of the <br />water monitoring program at the Southfield mine. EFCI maintains their position that the monitor well at <br />issue, MW -NW, is functional for water monitoring and sampling purposes in its current condition and <br />that changes to the well are needless, a waste of time and generates a great deal of expense, especially <br />considering that EFCI is required to seal and reclaim monitor wells prior to final bond release as is <br />documented in the approved Southfield permit. <br />However, the following information describes the proposed location, drilling procedure and <br />construction of a replacement monitor well (MWNW-2) to abate the alleged issues with the existing <br />monitor well, MW -NW. Extensive consultation with two drilling companies has determined that to <br />attempt to drill out the partial obstruction in MW -NW would be of high risk of getting the drill stuck in <br />the damaged steel casing and even though nitrogen gas was planned to be used during drilling, there is <br />still the risk of sparks while cutting through the steel casing resulting in a potential explosion from <br />methane and/or an underground mine fire. A letter from the drilling company, Young Drilling Company, <br />is attached in Appendix "A" with this submittal recommending that a replacement monitor well be <br />installed rather than attempting to drill out the partial obstruction in MW -NW. <br />The replacement monitor well (MWNW-2) is proposed to be located 280 feet SSW of the <br />existing MW -NW well. Coordinates for MWNW-2 are, 11183.95996N, 10027.64063E on the Southfield <br />mine grid system as depicted on the Southfield Mine Final Closure map. Latitude and Longitude <br />coordinates are, 38d17'24.35650"N, 105d09'43.64962W, NAD83. The new site is on the Vento property <br />located over the 1-1/2 North Section of the Southfield mine. The 1-1/2 North Section is mined out, <br />pillared and caved. Weaver Engineering Services has projected the elevation of the floor in the Red <br />Arrow seam at the proposed MWNW-2 site to be 5847.4 feet elevation which is 3.1 feet lower in <br />elevation than the floor elevation (5850.5) at the existing well, MW -NW. The depth of MWNW-2 is <br />projected to be 396 feet to the floor of the Southfield mine workings. A description of the drilling <br />procedure prepared by the drilling contractor is attached in Appendix `B" with this submittal. As <br />