2013-07-26_REVISION - C1981014 ‎(2)‎

• Permit No: C1981014
• IBM Index Class Name: REVISION
• Doc Date: 7/26/2013
• Doc Name: 2nd Submittal Change Request for Monitoring Well MW-NW
• From: Energy Fuels Coal Inc
• To: DRMS
• Type & Sequence: TR40
• Email Name: JHB
• Email Name: DIH
• Media Type: D
• Archive: No

energy fuels coal, inc.
southfield mine • post office box 459 • florence, colorado 81226 • (719) 784 -6395
July 23, 2013
Ms. Janet Binns — Reclamation Specialist
Colorado Division of Reclamation Mining & Safety
1313 Sherman St — Room 215
Denver, CO 80203
RE: Technical Revision No.40 (TR -40) - Southfield Monitor Well MW -NW
Energy Fuels Coal, Inc. — Permit No. C -81 -014 — Southfield Mine
Dear Janet Binns:
L1
Energy Fuels Coal, Inc (EFCI) submitted Technical Revision Request No.40 (TR -40) December 21,
2012, in which EFCI requested approval of a change in the groundwater monitoring point in monitor well
MW -NW. The TR was filed in response to NOV No. CV- 2013 -002 which sited EFCI for failing to ensure
that monitoring well MW -NW continued to function as designed. The NOV is currently on appeal to the
Mined Land Reclamation Board (the "Board "). The Division found that the Technical Revision was
incomplete in part because it lacked adequate technical and engineering support of the contention of EFCI
that the proposed monitoring point satisfied the monitoring requirements for MW -NW contained in
EFCI's permit. EFCI has not, prior to the date of this letter, submitted additional support for TR -40.
EFCI has now obtained additional hydrologic information and support data pertaining to the monitor well
MW -NW in the context of the Southfield mine's hydrogeology. As detailed below, the additional
information and evaluation demonstrates that MW -NW is not required to provide sufficient data to
evaluate the impacts on the groundwater regime at Southfield and the potential impacts thereto from
mining at Southfield.
Accordingly, EFCI hereby revises TR -40 to request approval to terminate further groundwater monitoring
in monitoring well MW -NW and eliminate MW -NW from the groundwater monitoring program.
EFCI has acquired further hydrogeologic information concerning the Southfield mine and MW -NW from
research and modeling data generated by the consulting firm Bishop - Brogden Associates, Inc., (`BBA "),
of Denver Colorado. EFCI requested that BBA review the goals and requirements of the section of
EFCI's permit establishing the groundwater monitoring program and evaluate those requirements using
the current available information as reported in, among other sources, the annual hydrology reports for
Southfield and a "report (Hydrologic Review) prepared by the Division's hydrologist.