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energy fuels coal, inc. <br />southfield mine • post office box 459 • florence, colorado 81226 - (719) 784-6395 <br />December 31, 2015 _ <br />Mr. Rob Zuber, P.E., Environmental Reclamation Specialist <br />Division of Reclamation, Mining, and Safety JAN U L <br />1313 Sherman ST, Room. 215 Division of Reclamation, <br />Denver, CO 80203 Mining & Safety <br />Re: Response to Bond Release Application No. 3 (SL -03) - Adequacy letter <br />Southfield Mine (Permit No. C-1981-014) <br />Dear Mr. Zuber: <br />Energy Fuels Coal Inc. (EFCI) has reviewed your adequacy review questions in your letter of December <br />18, 2015 concerning Bond Release Request No. 03 (SL -03). This letter and its attachments are intended <br />to provide all the requested information necessary to approve SL -03. Each DRMS adequacy question is <br />repeated for reference (by number), shown in bold, and followed by EFCI's response. For adequacy <br />questions requiring submittal of materials to the application, EFCI is enclosing 3 copies of each item to be <br />replaced or added to the application copies on file with the Division. <br />1. On page 5, the paragraph on Phase 1 bond release has an error. It states, "It also requests a <br />Phase II and Phase III release of the aforementioned Phase I areas ..." This is not entirely <br />accurate as the application only asks for Phase I for the substation. <br />RESPONSE: <br />Text was added to page 5 of the application text to clarify that a Phase II and Phase III bond release is <br />not being requested for the 0.5 acre substation area. Although the substation site was not originally <br />mentioned in this paragraph, the reader was directed to the Southfield Acreage Table, Appendix K, <br />where it clearly shows that the substation acreage is subject to Phase I only bond release request. <br />Replacement copies of page 5 are enclosed. <br />2. The Monarch Fan road is shown as an area of interest on the bond release map (Appendix B), <br />but it is not discussed. <br />RESPONSE: <br />Bond Release SL -02 granted Phase I bond release for the road to the Monarch Fan (also known as and <br />referred to in the SL -02 written findings as "the South Fan road"). Text narrative on page 15 of the SL - <br />02 written findings states "This road was also an existing road and is used to access a private <br />residence that is close to the reclaimed fan. This road has been permitted as permanent." Two <br />paragraphs later, on the same page, the findings states "All other roads that were apart of the <br />Southfield Mine were removed during reclamation. The Division finds that the roads have been <br />backfilled and graded, incorporating appropriate drainage control, as required by the approved <br />reclamation plan. " As is the policy at the DRMS, reclamation costs for approved permanent features <br />like roads, ponds, and buildings remain in the reclamation cost estimate until those features are <br />