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Energy Fuels Coal, Inc — Southfield Mine <br />Permit No. 1981-014 <br />RISK AND ECONOMIC EVALUATION TO REDRILL OR RELOCATE MW -NW MONITOR <br />WELL <br />This outline is a list of safety risks and excessive costs projected for either drilling out the partial <br />obstruction in monitor well MW -NW or drilling a new replacement well (MWNW-2) in the vicinity of <br />MW -NW located at the Energy Fuels Coal, Inc. (EFCI) Southfield mine. <br />UNDERGROUND FIRE: The adjacent landowner, The Corley Company (Corley), has emailed (5- <br />22-15) the Division of Reclamation Mining and Safety (DRMS) stating their concern of a potential <br />explosion and/or ignition of an underground mine fire due to encountering methane gas when drilling into <br />the Southfield underground mine workings. Corley has good reason for concern given that an <br />underground coal fire has been burning continuously on their property for 40 years. Allegedly, the <br />underground fire was started from the open pit surface mining operation in the Rex Carbon coal seam <br />during the 1970's which was located just west of the MW -NW site. A confirmation of the underground <br />fire is reported during 1996 or 1997 when a subsidence sinkhole that developed into shallow abandoned <br />mine workings in the Rex Carbon seam was reported on the north shoulder of the County Road 15 <br />roadway. Coal smoke and fumes were being emitted from the sinkhole. The sinkhole was reported to the <br />Division and OSM and the Abandoned Mine Lands (AML) responded by filling and sealing the <br />subsidence sinkhole. The sinkhole was located a few hundred feet west of the intersection of County <br />Road 15 and the Thompson driveway which is a distance of approximately 1,200 feet from the proposed <br />MWNW-2 site and MW -NW. Given that the underground fire has burned for years, the current location <br />of the fire is unknown except that it would be in the vicinity immediately west of the MW -NW site. <br />METHANE: Concerning the presents of methane gas in the Southfield mine, methane readings were <br />taken during mining operations while the mine was being ventilated so the accumulation of methane after <br />the mine was closed and sealed is unknown. However, it is reported by former employees that the <br />methane had accumulated during operations in the 4a' and/or 5a' South Mine Section to a potentially <br />explosive range of over 5% methane (explosive range, 5% to 15% methane). Electrical power to the <br />underground was shut down and all personnel exited the mine immediately until proper ventilation could <br />be reinstalled in the mine. <br />The integrity of the mine seals is unknown due to ground pressures but much of the Main Entries <br />are unsealed and methane, being lighter than air, would tend to accumulate toward the upper elevations of <br />the mine workings. MW -NW and the proposed MWNW-2 site are located in the upper elevations of the <br />Southfield mine workings. <br />NITROGEN APPLICATION: Given the concern of encountering methane gas in the mine workings, <br />nitrogen injection has been included in the drilling procedures as a safety factor to avoid a potential <br />explosion and/or underground mine fire. Never the less, even though nitrogen is included with the drilling <br />procedure as a safety factor, there is still a substantial risk of creating an explosion and/or mine fire. This <br />is evident in that a Blow -Out Protection (BOP) device is required to be installed at the well head in <br />