2015-10-13_REVISION - C1981014 (4)

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Energy Fuels Coal Inc. Application for Bond Release — October 2015 Appendices G and H contain the detailed vegetation monitoring data for 2013 and 2014 required to demonstrate that revegetation standards have been achieved. For Phase II, an applicant must demonstrate success with regard to plant cover and species composition. The results for 2013 and 2014 with regard to plant cover and species composition are stated in the Executive Summary and also in the Conclusions sections of the 2013 and 2014 Revegetation Monitoring Reports. All standards were met as required for Phase II bond release. As confirmed in the Division Permit Renewal No. 6 (RN -06) written findings, cropland or prime farmland is not present within any of the areas proposed or approved for disturbance at the Southfield Mine. An alluvial valley floor was identified on Oak Creek adjacent to the Southfield loadout. The written findings determined activities could proceed without impact to the AVF. Technical Revision No. 37 (TR -37) terminated water monitoring along Oak Creek. Topsoil thickness data, soil sampling, and maps are included in Appendix C. Topsoil redistribution and sampling requirements are detailed in Section 2.05.4 of the approved Southfield Mine permit application. The required average replacement thickness at the mine facility area is approximately 6 inches. A six-inch requirement is also in place at the Loadout. The required average replacement thickness for "A horizon" topsoil at the RDA is approximately 12 inches. Testing and field observations confirm that topsoil was re -distributed as per the approved plan. Appendix D contains sediment -modeling calculations for the Southfield Mine site and the Loadout. The Revised Universal Soil Loss Equation was used in conjunction with site specific data for soils, slopes, rainfall, hydrologic cover and land management practice. Results indicate that the reclaimed areas produce less sediment than adjacent non -mined areas. Ponds 4 and 5 were approved as permanent via TR -42 and TR -44. The ponds are routinely inspected during monthly DRMS inspections and continue to be inspected quarterly by the operator. SL -03 Request for Phase III Bond Release Please refer to the Southfield Acreage Table in Appendix K. In the fifth column of this table the Phase III acreage status is detailed for all of the mine areas. At the top of the column, highlighted in yellow, 106.3 acres remain to be Phase III bond released. For this application, EFCI requests Phase III bond release for 102 acres. Those areas are highlighted in the fifth column in green. Excluded are 4.3 acres of areas which are not eligible for Phase III release at this time. The 2014 Annual Reclamation report in Appendix I provide evidence through text narrative and maps that the ten-year liability period has been achieved for the reclaimed areas for which a Phase III bond release is requested. Additional maps are included in revegetation monitoring reports included in Appendices G and H. The primary purpose of Phase III revegetation monitoring is to determine if the final revegetation success criteria had been satisfied for the reclaimed areas of the mine site and loadout. For Phase III bond release, an applicant must demonstrate success with regard to allowable plant cover, forage production, warm season grass species diversity and shrub density. The results for 2013 and 2014 with regard to plant cover and species composition are stated in the Executive Summary and also in the Conclusions sections of the 2013 and 2014 Revegetation Monitoring Reports. All standards were met as required for Phase III bond release. Please refer to Appendices G and H for specific details. Surety Release No. 3 (SL -03) Southfield Mine