2016-09-16_REVISION - C1981014 - Laserfiche WebLink

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The Corley Company 2605 Constellation Drive Colorado Springs, Colorado 80906 September 16, 2016 Mr. Robert D. Zuber Colorado Division of Reclamation, Mining and Safety 1313 Sherman St., Room 215 Denver, Colorado 80203 Dear Mr. Zuber: In response to your notice of proposed approval of Bond Release Application No. 4 (SL -4) for the Southfield Mine, The Corley Company objects to the release and hereby requests an adjudicatory hearing. In the Revised Reclamation Agreement (RRA) between The Corley Company and Energy Fuels Coal, Inc., dated March 18, 2016, we agreed to support the bond release application SL -4 which had been submitted January 22, 2016. This original bond release application did not include the release of the area impacted by the required removal of the Magpie Spring structures. Subsequently, a revised application and map dated April 3, 2016, were submitted adding item 10, the Magpie Spring Structure Area. We were not informed prior to the RRA that the Magpie area was going to be added to the original SL -4 application by means of a revised SL -4 application on April 3, 2016, and we cannot support this revised SL -4 application. We believe that the construction of the Magpie Diversion channel after removing the Magpie Spring and delivery pipeline for approximately 150 feet does not meet the design specifications as set forth in the Southfield Map 25A. The tracks left by the excavator used in the spring and pipeline removal have not recovered in more than two months following the work, and there is no evidence of successful reclamation. A section of the pipeline has not been removed. The RRA requires mitigation of the fire in the GEC waste pile which was undermined and at the edge of a pillared panel of the Southfield Mine. This work has not been initiated. The extent of this work is unknown, and we assume that it will be included in a SL -5 application for release. Sincerely, W.D. Corley, Jr. President, The Corley Company