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20. On page 2.05.6 -27 of the PAP the text refers to a permit area expansion <br />proposed by a revision. This language is not appropriate for the PAP and should be <br />revised. <br />Attached revised page(s): <br />2.05.6 -27 <br />21. Within the subsidence portion of Section 2.05.6 of the PAP, there is no discussion of <br />potential impacts of subsidence on renewable resource lands. Please explain this, <br />especially in the context of potential groundwater recharge. <br />Attached response — Section 2.05.6 <br />22. RE: Structures and potential subsidence: <br />Attached revised pgs: <br />2.05.6 -55 (3 pgs) <br />2.05.6 -57 (2pgs) <br />2.05.6 -64 <br />2.05.6 -66 (2 pgs) <br />23. Introductory text describing current or recent status of the mine and loadout is attached for <br />insertion in the applicable sections of the permit. The respective sections are shown on the <br />revised pages for insertion into the permit document. <br />24. Page 4.05.6 of the PAP does not flow with the previous page and needs to be <br />revised. <br />Attached revised page(s): <br />4.05 -5a <br />4.05 -6 <br />25. Buffer Zones: EFCI mining activities commenced in 1985 and ceased with permanent <br />mine closure in December, 2000. Demolition of facilities and reclamation activities then <br />commenced. The Southfield mine is currently in Year 10 of the 10 Year Reclamation Liability <br />Period. The Loadout site is in Year 15 of it's liability period. The Division approved EFCI's <br />mining/reclamation permit wherein it states that buffer zones are not required (pg 4.05 -29) for <br />the Southfield operations. In so doing, the Division authorized underground mining through the <br />area streams. Given that mining operations have long since ceased, EFCI has no intent of further <br />disturbance to the area(s). <br />If you have any questions or need additional information please contact me. <br />Sincerely, <br />JU rge V Patterson <br />Energy Fuels Coal, Inc. <br />