2013-08-29_REVISION - C1981014

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 8/29/2013
• Doc Name: Preliminary Adequacy Concerns
• From: DRMS
• To: Energy Fuels Coal, Inc
• Type & Sequence: TR40
• Email Name: JHB
• Email Name: DIH
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
August 29, 2013
George Patterson
Energy Fuels Coal, Inc.
P.O. Box 459
Florence, CO 81226
Re: Southfield Mine (Permit No. C- 1981 -014)
Technical Revision No. 40 (TR -40)
Preliminary Adequacy Concerns
Dear Mr. Patterson:
COLORADO
ID IV I S I O N O F
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pineda
Director
The Division has reviewed EFCI application for technical revision No. 40. EFCI provided copies
of mine water inflow volumes from EFCI's 1995, 1997, 1998, 1999, and 2000 Annual Hydrology
Reports, and an evaluation prepared by Bishop - Brogden Associates (BBA) describing three
potential scenarios. After review of the BBA report and the information provided by EFCI, the
Division has the following adequacy questions:
As stated on Page 3 of the Bishop Brogden Associates report, "the Southfield permanent
closure map, dated august 2001, was used to identify area and volumes within the mine
above and below elevations of interest." This is a key component in each of the
Conceptual Models and would require detailed calculations. Please provide a list of
assumptions used and an explanation of how the total mine volumes presented in
Conceptual Models 1 through 3 were calculated.
2. The 14 acre -feet per year inflow to the 1 North and 2 North areas is also a key factor in
each of the three models. As stated in the report, there is no inflow information for the 1
North and 2 North areas for 1998, 1999, or 2000 and previous records are misleading
because of the use of these areas as reservoirs and pumping from these areas. This
critical factor utilized in each model calculation is based solely on observations by EFCI
personnel. Please provide a more detailed explanation of the methodology used by EFCI
personnel to estimate this mine inflow value and provide the assumptions used in the
estimate of 14 acre -feet per year.
Conceptual Model No 2 and Conceptual Model No. 3 in the BBA report both make
assumptions that there is some degree of separation of the northern mining area: 1 north,
1' /z north, and 2 north. However, model no. 3 introduces the 3 north mining area into the
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