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energy fuels coal, inc. <br />southfield mine - post office box 459 - florence, colorado 81226 - (719) 784-6395 <br />August 21, 2015 <br />Mr. Rob Zuber - Environmental Reclamation Specialist <br />Colorado Division of Reclamation Mining & Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />RE: Decision Date Extension Request - Technical Revision No.43 (TR -43) Terminate <br />Water Monitoring Program <br />Energy Fuels Coal, Inc. (EFCI) - Southfield Mine - Permit No. C-81-014 <br />Dear Rob Zuber: <br />EFCI requests that the decision deadline for TR -43 be extended to September 30, 2015. This <br />extension is requested to allow the Division time to review the adequacy response for TR -43 <br />that EFCI will submit within the next week. <br />TR -43 is important to EFCI for a couple of practical reasons. First, approval of TR -43 allows <br />the termination of water monitoring activities that have been on-going over the reclamation <br />liability period. In the case of the Southfield Mine, monitoring has been ongoing for 13 years <br />following mine closure and reclamation. As you are aware, water monitoring normally <br />continues through the reclamation liability period to provide data adequate to show that <br />impacts within the permit boundary have been minimized and that impacts outside the permit <br />area have been prevented. Approval of surface and ground water monitoring will allow EFCI <br />to complete their reclamation obligation to seal ground water monitoring wells prior to a <br />request for final bond release in accordance with Rule 4.07. It is EFCI's intention to complete <br />the required sealing of applicable ground water wells at the Southfield Mine in calendar year <br />2015. <br />Secondly, EFCI is working diligently toward submittal of an application for final bond release <br />in 2015 for much of the disturbed area as allowed under the Coal Rules. Numerous <br />consultants are working to put this application together, which includes a request for a Phase <br />II and Phase III release for the vast majority of the area covered under the reclamation bond. <br />Vegetation monitoring data was collected in 2013 and 2014 and as suggested by the Bond <br />Release Guidelines, timely submittal of this bond release, application is warranted. Final <br />inspection cannot be completed until wells are sealed. EFCI is committed to complete this <br />work but also must plan and schedule accordingly, without regard to the potential for future <br />landowner objections. It is EFCI's position that postponing or delaying work towards final <br />bond release or asking that EFCI stand idly by while waiting for consensus or approval from <br />the landowners is counter-productive and inhibits EFCI's ability to complete it's obligations <br />under the approved mining permit. While EFCI is well aware of the rights of interested <br />parties to comment and/or object to revisions and bond release requests, likewise, it is entirely <br />within the rights of EFCI to continue to work towards final bond release as allowed under the <br />Coal Rules. <br />