2012-12-18_REVISION - C1981014 - Laserfiche WebLink

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energy fuels coal, inc. southfield mine • post office box 459 florence, colorado 81226 (719) 784 -6395 December 14, 2012 Ms. Janet Binns — Reclamation Specialist Colorado Division of Reclamation Mining & Safety (DRMS) 1313 Sherman St — Room 215 Denver, CO 80203 RE: Minor Revision No.59 (MR -59) Revise Subsidence Monitoring Schedule Energy Fuels Coal, Inc. - Permit No. C -81 -014 - Southfield Mine Dear Janet Binns: Energy Fuels Coal, Inc. (EFCI) requests approval of Minor Revision No.59 (MR -59) to revise the Subsidence Monitoring Schedule at the Southfield mine. Previously, in a letter to the DRMS dated July 30, 2012, (copy enclosed) EFCI requested postponing the Southfield Vegetation Monitoring to one year later than scheduled due to the continued drought conditions in the area. DRMS approved the request which thereby extended the Southfield Reclamation Liability Period one year later, from 2013 to 2014. In concurrence with the vegetation monitoring extension request, in the same letter of July 30, 2012, EFCI requested postponing the Southfield Subsidence Monitoring Schedule to coincide with the extended Reclamation Liability Period, now extended to 2014. However, the Division denied approval and in the DRMS' December 2012 Southfield Inspection Report, the DRMS has directed EFCI to complete the subsidence monitoring by the end of year 2012. With MR -59, EFCI submits that the subsidence monitoring schedule as approved in the Southfield Permit Document was scheduled in TR -36 (2003) to document long term surface subsidence effects and scheduled surveys for years 3 and 9 (2006 and 2012) of the reclamation liability period. The scheduling was based on the assumption that the Reclamation Liability Period would be the typical ten (10) year period and therefore scheduled the final subsidence monitoring in next to the last year of the liability period which was projected for year 2012. In accordance with Rule 2.05.6(6)( c)( i )(F), EFCI submits that the subsidence monitoring be extended to coincide with the liability period which allows time beyond cessation of mining and the reclamation activities and consistency with the need for verification of the subsidence predictions. Additionally, landowner The Corley Company, has expressed concerns to the Division and EFCI about subsidence in various areas of the mine (albeit within the subsidence predictions). Vento, et al, has expressed concerns of subsidence as well. Extending the final subsidence survey to a later date will allow more time for any potential subsidence, if any, to occur. Accordingly, MR -59 reschedules the final subsidence survey to Year 10 (2013) of the reclamation liability period. Respective text has been revised in TR -36 to reflect these changes. Copies of revised pages are enclosed with this submittal to be inserted in the permit document.