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energy fuels coal, inc. <br />southfleld mhos • post office box 459 • florence, Colorado 81226 • (719) 784-6395 <br />August 25, 2015 <br />Mr. Rob Zuber, Environmental Reclamation Specialist <br />Division of Reclamation, Mining, and Safety <br />1313 Sherman St, Rm. 215 <br />Denver, CO 80203 RECEIVED <br />Re: Response to Second Adecp<acy Review AUG 2 8 2015 <br />Technical Revision No. 43 (TR43) <br />Southfield Mine (Permit No. C-1981-014) DIVISION OF RECLAMATION, <br />MINING AND SAFETY <br />Dear Mr. Zuber: <br />Energy Fuels Coal Inc. (EFCI) has, reviewed your second round of adequacy review questions in your <br />letter of April 23, 2015 concerning Technical Revision No. 43 (TR43). In this review letter the Division <br />suggests that EFCI withdraw TR -43, or request an extension of the proposed decision date, to allow time <br />for the abatement of NOV C-2013-002. At this time the NOV has been formally vacated, subjectto <br />appeal. Since so much information has previously been submitted, it is more efficient to keep TR -43 in <br />process instead of withdrawing it. <br />EFCI proposes to continue processing this revision for approval in advance of applying for final bond <br />release. We anticipate filing the bond release application in the next 30 to 60 days. If we wait to terminate <br />water monitoring as part of the bond release decision, EFCI will not be able to seal monitoring wells <br />without approval of TR -43; but the Division can't approve bond release until all of the holes are <br />plugged. <br />This letter and its attachments are therefor intended to provide all the requested information necessary <br />to approve TR -43. Each DRMS adequacy question is repeated for reference (by number), shown in bold, <br />and followed by EFCI's response. <br />1) a) DRMS concern <br />There are several apparent gaps in the data record, including from June 1986 to May 1958, and <br />from July 1995 to June 19%, which coincided with a period where the operator was not able to <br />sell coal. Does EFCI have records available for either of these periods? <br />EFCI response <br />It is not clear if this question relates to groundwater monitoring at the monitoring wells, or monitoring <br />of mine inflows within the active workings. In any case, all such monitoring was done and summarized <br />