2013-02-14_ENFORCEMENT - C1981014

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energy fuels coal, inc. southfield mine • post office box 459 • florence. colorado 81226 • (719) 784 -6395 February 14, 2013 Ms. Janet Binns — Reclamation Specialist Colorado Division of Reclamation Mining & Safety 1313 Sherman St — Room 215 Denver, CO 80203 RE: Response to Receipt of Citation No. CV- 2013 -002 — Monitor Well MW -NW Energy Fuels Coal, Inc. — Permit No. C -81 -014 — Southfield Mine Dear Janet Binns: This is in response to receipt of Citation No. CV- 2013 -002 concerning the monitoring well MW- NW located at the Southfield mine. Energy Fuels (EF) submits the following information in accordance with Section 5.04.3(1) of the Rules and Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. COMPLIANCE WITH REGULATIONS CITED IN NOV: EF hereby reconfirms its prior position that it is in compliance with the regulations that the NOV alleges has been violated. Specifically, EF asserts that Monitor Well MW -NW was specifically found by DRMS to be in compliance during an inspection in April, 2012. See Inspection Report dated April 17, 2012 which concludes that "this well serves the purpose of detecting, measuring and sampling water in the flooded Southfield mine workings ". There has been no physical change to Monitor Well MW -NW since the date of that inspection so EF asserts the NOV should be vacated. In support of this position, EF has previously submitted information, verbal and written, and the highlights of that information are summarized below for ease of reference. MINE ROOF: The original distance between the elevation where the obstruction in the well is believed to be and the roof of the mine workings was approximately twenty (20) vertical feet. The MW -NW lower extent of the well casing protruded into the center of the intersection of the mine entry and crosscut of the mine workings. The area of the intersection was approximately 20 horizontal feet by 20 horizontal feet. EF believes that roof falls (caving) of the roof intersection caused the `initial' blockage and partial obstruction in the well casing by stretching, tearing and/or bending the lower section of the well casing at the point of the blockage. Due to the caving, it is likely that the area between the obstruction in the well bore and the mine workings is now a void. BLOCKAGE: In response to concerns of the adjacent landowner that the well may be plugged, in good faith, on March 22, 2012, EF probed the well using a wooden block as a weight to measure the well depth. The probe line measured 354 ft below the top of the well casing where it encountered a blockage. Given the disfigurement of the pipe and/or blockage in the casing at that point, the wooden block (2 "x4 "x8 ") became lodged and could not be removed.