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2015-08-28_REVISION - C1981014
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2015-08-28_REVISION - C1981014
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Entry Properties
Last modified
8/24/2016 6:10:15 PM
Creation date
9/29/2015 9:45:58 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
8/28/2015
Doc Name
Response to 2nd Adequacy Review
From
Energy Fuels Coal, Inc
To
DRMS
Type & Sequence
TR43
Email Name
LDS
JRS
Media Type
D
Archive
No
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TR -43 Adeauacv Responses Page 4 August 25 2015 <br />(Hydrology Monitoring Plan) stating that applicable hydrologic monitoring was terminated by approval <br />of TR43. The revised preface, and revised PAP pages 2.04.7-7a, 2.05.6-51, 2.05.6-51a, 4.05-25, 4.05- <br />26, and 4.05-27 are attached hereto for your review. <br />1) d) i) DRMS concern <br />Please provide a detailed analysis of the impact of the Southfield Mine on groundwater quality, <br />allowing the identification of trends in the data (perhaps a selection of individual water quality <br />parameters could be plotted against time, for example: TDS, [Fe], [Mn],[Se]... ) <br />EFCI response <br />EFCI has updated groundwater quality data, through the 2nd quarter of 2015, on the graphs attached <br />hereto in Appendix A. These data indicate that MW 16 held water for the first time since going dry in <br />2006, and a sample was taken in June 2015. The region received unusually high precipitation during <br />May and June 2015, which evidently temporarily recharged the zone monitored by the well. Samples <br />were also obtained from MW23 and MW65, while MWNW was dry. Based on the new data and <br />review of the "2015 Weaver Analysis" (previously submitted) of the impact of the Southfield Mine to <br />the quality of groundwater, the aforementioned analysis is accurate. <br />1) d) ii) DRMS concern <br />Please include data collected from each groundwater monitoring point in the analysis, including <br />MWNW (which may be dry), in accordance with the approved water monitoring plan described <br />in Exhibit 25, and make a comparison to predictions made in the PAP. <br />Items 1) d) i) and ii) have not yet been addressed to the Division's satisfaction. <br />The 2015 Weaver Analysis is appropriate in its approach, but will need to be resubmitted with <br />the additional data available fofiowing the abatement of NOV CV -2013-002. <br />EFCI response <br />Same as response to Item 1) d) i), above. <br />2) a) DRMS concern <br />Please continue to follow the approved water monitoring program, and to attempt to monitor the <br />creeks during times of high flow. The response is noted. Please continue to follow the approved <br />water monitoring program. <br />EFCI response <br />EFCI continues to follow the approved hydrology monitoring program as evidenced by the data <br />collected and presented with this submittal. EFCI diligently conducted numerous field trips to obtain <br />samples from creeks during the spring of 2015, as all flowed due to the unusually high amount of <br />rainfall. <br />
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