2015-06-12_REVISION - C1981014 (2)

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RELOCATION FOR MWNW-2: The 1st North Mine Section where the existing MW -NW monitor well is located is in a section of the mine having very poor roof conditions. During mining operations in the 1st North Section, there were so many roof falls that it was deemed too unsafe to pillar and cave (retreat mining phase) the 1st North Section. The lack of pillaring and documented roof falls in the 1st North Section are depicted on the Southfield Mine Final Closure Map. A solid coal barrier separates the 1st North Section and the 1-1/2 North Section of the mine. During mining operations, the mine roof conditions were more stable in the 1-1/2 North Section. The retreat mining phase was executed and 1-1/2 North Section was pillared /caved. The proposed location for drilling MWNW-2 is in the 1-1/2 North Section due to the greater stability of the strata experienced in that mine section. It is believed that while drilling into the mine workings, there would be less caving of the borehole as compared to drilling into the unstable strata in the 1st North Section. It is understood that there will be a rubble zone in 1-1/2 North due to the pillaring operation but it is believed that the strata above the rubble zone is more preferable for drilling than in the 1st North Section. The drilling technique for penetrating the rubble zone is explained in TR -46 wherein a drill bit is welded onto the end of the well casing prior to installation, the well casing is then rotated during the insertion of the well casing through the rubble zone and the casing (with drill bit attached and perforations in the wall of the casing) is left permanently in place resting on the floor of the Southfield mine workings. Additional reasons for selecting the proposed location include minimal additional surface disturbance, and the elevation of the target Red Arrow seam is approximately the same as MW -NW. Given the aforementioned unstable roof conditions in 1st North, the only choice is to attempt to drill into a pillared area of the mine in the close proximity to MW -NW since all these areas were pillared. Further, it is believed that because the existing well casing in MW -NW in 1st North failed due to ground pressures and/or possible roof falls, the more stable strata in 1-1/2 North offers a better chance of the well casing in MWNW-2 to remain in a stable condition. Again, to continue the festering issue concerning the bottom 5% of vertical length of the existing MW -NW well is unwarranted considering the safety risks involved and the unreasonable cost to obtain a meager amount of information of water quantity and quality, particularly when coal mine water is predicted to be of degraded quality anyway. Detail of the drilling procedure and the related cost estimate was included in the TR -46 submittal, however, for ease of review, copies of the proposed drilling cost/procedure are attached hereto. George V Patterson Mine Manager Energy Fuels Coal, Inc.