2016-01-14_REVISION - C1981014

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 1/14/2016
• Doc Name: 2nd Adequacy Review
• From: Energy Fuels Coal, Inc
• To: DRMS
• Type & Sequence: SL3
• Email Name: RDZ
• Email Name: JRS
• Media Type: D
• Archive: No

energy fuels cel, inc.
southfield mine - post office box 459 - florence, colorado 81226 • [phone]
January 13, 2016 RECEIVED
Mr. Rob Zuber, P.E., Environmental Reclamation Specialist JAN 14 2016
Division of Reclamation, Mining, and Safety DMSlON OF RECLAMATION
1313 Sherman ST, Room. 215 MININGANDSAFETY
Denver, CO 80203
Re: Response to Bond Release Application No. 3 (SL -03) — Second Adequacy letter
Southfield Mine (Permit No. C-1981-014)
Dear Mr. Zuber:
Energy Fuels Coal Inc. (EFCI) has reviewed your adequacy review questions in your letter of January 8,
2016 concerning Bond Release Request No. 03 (SL -03). This letter and its attachments are intended to
provide a response to Question #12, which requests a minor revision. For a response as a minor revision,
EFCI is enclosing 3 copies of revision materials and an application form for a minor revision. A response
to Question #3 will be submitted later, as noted below.
3. The Division understands that the reference to Attachment I was a mistake; no additional
response required. Regarding EFCI's explanation as to why the LS factors for the reclaimed
areas and the non -mined areas are identical, the Division still believes that is best to assess the LS
parameter separately: the post -mining condition should be based on the current topography of
the areas where bond release is sought, whereas the pre -mining condition should be based on the
pre -mining topography of the actual location of the RDA and facilities area or on the topography
of adjacent unmined areas. Also, Map 13 and 29 are referenced in the sediment demonstration
for the mine site; however, these maps are related to the loadout. Please correct this error.
RESPONSE:
EFCI is revising the sediment demonstration for the mine site and RDA in accordance with suggestions
from the Division, and is using Map 33 to obtain topographic information for the demonstrations rather
than Maps 13 and 29. Revised sediment demonstrations will be submitted in a subsequent response.
12. It is necessary that a Minor Revision, designating stockpiles as permanent features, be
approved prior to approval of SL -03. This is necessary because of Rule 4.14.2, which addresses
grading requirements and the need for approximate pre -mining slopes. Under separate cover,
the Division will provide EFCI with details regarding this revision.
RESPONSE:
With this letter EFC1 is submitting Minor Revision No. 70 (MR -70) addressing the permanent topsoil
piles at the mine site. Attached revision materials for a minor revision include the following: