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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />9 October 2003 <br />Mr. George Patterson <br />Energy Fuels Coal, Inc. <br />PO Box 459 <br />Florence, CO 81226 <br />Re: Technical Revision No. 36 (TR-35) <br />Southfield Mine (C-81-014) <br />Dear Mr. Patterson, <br />The Division has completed its adequacy review of Technical Revision 36 -changes to <br />the subsidence-monitoring program to reflect post-mining conditions. The Division <br />believes that the subsidence predictions have been adequately validated. Further, the <br />Division believes that the proposed monitoring program should be sufficient to provide <br />meaningful information when release from liability of areas overlying underground coal <br />mine workings is considered. Below aze questions the Division has regazding the <br />submittal. <br />1. On Pages 2.05.6-60 and 2.05.6-60a, EFCI states that monitoring will be <br />performed during years three and nine (post-reclamation). The Division <br />requests that EFCI change the text to specify the exact years that subsidence <br />monitoring will be performed (i.e. 2006 and 2012). This will eliminate any <br />confusion that may arise as to when years three and nine actually are. <br />COLORADO <br />DIVISION O F <br />MIN SRALS <br />GEOLOGY <br />RECLAMATION•MINING <br />EAFETY•SCIENCE <br />Bill Owens <br />Governor <br />Greg E. Walther <br />Executive Director <br />Ronald W. Cattany <br />Division Direcor <br />Natural Resource Trustee <br />2. Please update all text on pages 2.05.6-55 through 2.05.6-66R to eliminate the <br />reference to proposed actions, rather, have the text read that all operations <br />have been approved. For example, the text on page 2.05.6-55 that says "Since <br />measured subsidence over the past eighteen yeazs is well within the range <br />predicted by RMG in the original mine permit, EFCI proposes to eliminate <br />quarterly and semi-annual subsidence monitoring and reporting at the end of <br />2003." Should be changed to read "Since measured subsidence from 1984 <br />through 1995 is well within the range predicted by RMG in the original <br />mine permit, and progressive subsidence has virtually ceased, EFCI <br />proposed, and the CDMG approved, elimination of quarterly and semi- <br />annual subsidence monitoring and reporting as of the end of 2003." <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />