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DATE: January 29, 2008 <br />TO: Russ Means <br />FROM: Kate Pickford <br />RE: Hydrology Review of Energy Fuels Resources Corporation Response to <br />Preliminary Adequacy Review, File No. M-2007-044 Whirlwind Mine, <br />Mesa County, Colorado <br />The Division has reviewed the hydrologic content of Energy Fuels Resources <br />Corporation's Response to Preliminary Adequacy Review, File No. M-2007-044 <br />Whirlwind Mine, Mesa County, Colorado and submits the following comments. <br />Energy Fuels has stated that it is unable to fully define the groundwater regime at the site <br />and is relying heavily on historic information that was acquired when the mine was <br />previously operated by Umetco Minerals. Therefore some of the statements made in the <br />materials submitted by Energy Fuels, with regard to groundwater and the springs in the <br />area, are somewhat speculative in nature. <br />The Division is not convinced that the materials submitted accurately depict the <br />hydrologic system at the site. Therefore the Division has concerns related to the affects <br />of future activities on groundwater and surface water quality and impacts that may occur <br />as a result of installation of the proposed bulkhead at the site. The Division, however, <br />does not believe it would be appropriate to delay approval of the permit until the <br />hydrologic regime is fully defined, as it has typically required for other applications, <br />because the Division believes that the operator will acquire applicable information as <br />preparations are made to recommence mining activities at the site. <br />Therefore, the Division is willing to consider approval of the permit prior to submittal of <br />a complete hydrologic model of the site if Energy Fuels agrees to commit to performing <br />further activities aimed at defining the hydrologic regime at the Whirlwind site. Energy <br />Fuels should submit to the Division, prior to approval of the permit, a plan and timetable <br />for future activities that Energy Fuels will perform in order to further define the <br />hydrologic system at the site. Such activities may include dye tracer tests to determine <br />the fate of standing water in the Whirlwind decline and Packrat Mine, water level <br />measurements, groundwater mapping, and modeling. <br />Energy Fuels should be aware that depending on the outcome of such testing and <br />modeling, the Division may require a revision to the permit to accommodate the <br />conditions at the site. <br />