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In addition to the circumstances provided above, the third party sampling and analysis <br />represents a significant cost to Energy Fuels due to the remoteness of the site, the lengthy <br />sampling procedure, and high cost of laboratory analysis. The Whirlwind Mine is located <br />in a fairly remote area and the nearest environmental consultants available to provide <br />third party sampling is located in Grand Junction, approximately two hours travel time <br />from the site during good weather and significantly longer during poor weather. In <br />addition, the sampling protocol, designated by the WQCD, calls for composite samples to <br />be collected over an 8-hour period. The third party sampling requires a full 10- to 12- <br />hour day by an environmental consultant. The cost of this to Energy Fuels is <br />approximately $1,000. The additional laboratory costs for the analysis of third party <br />samples is $540. The total additional cost to Energy Fuels to provide third party <br />sampling and analysis is approximately $1,500 per event. Considering the circumstances <br />stated above, Energy Fuels feels that this cost is unwarranted and is an unnecessary cost <br />and hardship. <br />In summary, Energy Fuels feels that the samples and analytical data being provided to the <br />CDPHE and BLM in accordance with the WQCD discharge permit are accurate and <br />should be considered sufficient for monitoring of the treatment plant. Furthermore, the <br />volume of water that will be pumped and treated over the foreseeable future is expected <br />to be small and of better quality than the previous mine water that had been present in the <br />lower portion of the mine over an extended period of time. As the BLM is aware, Energy <br />Fuels recently agreed with the Colorado Division of Reclamation, Mining and Safety to <br />conduct on-going quarterly sampling, analysis, and evaluation of water within the mine <br />and nearby springs. The monies saved by eliminating the third-party sampling of the <br />treatment system could be used to fund this new program. <br />Please feel free to contact me at (303) 974-2151 if you need any additional information. <br />Sincerely, <br />Zach Rogers <br />Cc: Trey White, Frank Filas, Marty Olson, Chip Karo (Energy Fuels) <br />Russ Means (DBMS, Grand Junction) <br />{~,ncr~y I'rz~as, inc,. 44 tiniEZra 131vsa., Sttil~ 6:3C) <br />~+sv~s.~.rerg~ iiie;s.c+~rn !,<o.l.~:e~ssoci, (;r~l<>a~<~:!;t <';(?22~3 <br />I~']~r>nc: 3t33_t~~;r.~_2, t Vii} <br />F ax: 3(?3-9?~-~ 14 [ <br />