2014-09-16_REVISION - C1981014 (3)

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energy fuels coal, inc. southfield mine • post office box 459 • florence, colorado 81226 • (719) 784 -6395 O v September 1, 2014 Mr. Rob Zuber — Reclamation Specialist Colorado Division of Reclamation Mining & Safety 1313 Sherman St — Room 215 Denver, CO 80203 RE: Technical Revision No.42 (TR -42) Request — Convert Pond 4 to Permanent Structure Status Energy Fuels Coal, Inc. (EFCI) — Permit No. C -81 -014 — Southfield Mine Dear Rob Zuber: The Vento group, as landowners on which sedimentation Pond 4 at the Southfield mine is located, has formally requested that Pond 4 be retained as a permanent structure. EFCI is in receipt of signed letters from the entities that compose the Vento group, all parties requesting the permanence of Pond 4. The Vento group ( "Ventos ") entities are KT2, LLC and South Central Land and Mining, LLC. Copies of the signed letters are enclosed with this submittal. In a region where available water is a scarcity, retaining Pond 4 as a permanent impoundment will greatly enhance the approved post mining land use which is for undeveloped rangeland and wildlife habitat. Throughout the years of EFCI's mining and reclamation (1985 to date), numerous Elk in herds numbering from 12 head to 60 head have utilized Pond 4 as a source of water as well as the other pond at Southfield, Pond 5. Deer and other wildlife have frequented the ponds as well and the ponds are also a potential source of water for any future livestock watering. Pond 4 is located in the NE4, NW4 of Section 30, T20S, R69W of the 6`f' PM. Pond 4 is depicted on the Southfield Mine Area Surface & Groundwater Map, Map 12. This revision request (TR -42) addresses Rule 4.05.9(13) Permanent Impoundments: a) Suitable water quality for intended use, complying with applicable water quality standards and effluent limitations without degradation of downstream waters; Historically, Pond 4 has proven suitable in meeting applicable water quality standards. Pond 4 is an approved design impoundment being a self dewatering pond and does not contribute to degradation of downstream waters. The historical water quality analysis of the pond is included with this submittal. Pond 4 was redesigned from a manual water discharge system to a self dewatering pond in 2002. Given the design capacity and the capability to handle 24 hour, 25 year storm water events, water is retained in the pond and it has not been necessary to discharge since being redesigned in 2002. Consequently, due to the infrequent discharge, sampling for historical water quality data was rather limited.