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energy fuels coal, inc. i <br />southiMd mins - post off * box 159 • fbrance, Colorado 81226 • (719) 781-6395 <br />July 9, 2015 <br />Mr. Leigh Simmons <br />Division of Reclamation, Mining, and Safety <br />1313 Sherman St, Rm. 215 <br />Denver, CO 80203 <br />Re: Response to Initial Adequacy Review G• 215 <br />Technical Revision No. 46 (171146) <br />Southfield Mine (Permit No. C-1981-014)S,o� �F RD SON <br />OA NG RN <br />Dear Mr. Simmons: <br />Energy Fuels Coal Inc. (EFCI) has reviewed your initial adequacy review questions in your <br />letter of July 1, 2015 concerning Technical Revision No. 46 (TR -46), NOV CV -2013-002 <br />and well MW -NW. Each DRMS question is repeated for reference and followed by EFCI's <br />response. Also included in this adequacy response is additional information for your <br />consideration regarding attempts to secure a second cost estimate (bid) to re -drill this well. <br />1. DRMS concern <br />Please attempt to measure the concentration of methane within the mine workings. <br />This could be achieved by pumping air out of MW -NW and sampling the air <br />withdrawn from the cavity. <br />EFCI response <br />EFCI previously addressed the potential for methane in the mine workings in a document <br />titled "Risk and economic evaluation to redrill or relocate MW -NW monitor well" (Risk <br />Evaluation), dated June 11, 2015 which was submitted to the Division (via email <br />6/12/2015 10:41 am). We understand you did not consider that Risk Evaluation in your <br />adequacy review. Please do. <br />This information was in response to questions raised by the DRMS on May 27, 2015 in a <br />meeting with Gorham Energy Consultants, acting on behalf of EFCI. Please review this <br />information. As stated in our response, methane concentrations at dangerous levels were <br />recorded in the Southfield Mine over the period of active coal mining operations. <br />Controlling proper ventilation to mitigate dangerous levels of methane and other gases is <br />