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January 26, 2016 <br />Mr. Rob Zuber, Reclamation Specialist <br />Colorado Division of Reclamation Mining & Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Permit: Energy Fuels Coal, Inc. Permit number: C-81-014. <br />RE: Bond Release Field Review (Erosion) <br />Dear Mr. Zuber, <br />This letter is to express comments that Daryl E. Mergen, Carin J. Corley, and Mr. Jack Robeda <br />began to discuss during the bond release field visit on November 11 and 12, 2015 and our <br />concerns with the obvious erosion within the permit boundary and the sediment deposition and <br />erosion of County Road 92 (on either side of the green gate that spans County Road 92), just <br />north of Energy Fuels Coal, Inc.'s (EFCI) permit boundary. We believe most of the runoff and <br />sediment are coming from within the permit boundary. There was no evidence to the contrary <br />presented within either the sediment analysis or EFCI's response to adequacy questions. Our <br />main concern is that the amount of sediment and quality of water within and exiting the permit <br />boundary and eventually exiting the Corley property is greater than acceptable standards in the <br />Clean Water Act or perhaps greater than standards of the Colorado Department of Public Health <br />and Environment, the Colorado Department of Agriculture soil loss tolerance level, or the USDA <br />NRCS soil loss tolerance levels for Fremont County, Colorado. Soil loss tolerance has not been <br />discussed and recently EFCI raised the issue of suspended solids to streamflow in the January 13, <br />2016 sediment analysis report. <br />Until the January 13, 2016 version, the Southfield Mine Facility and RDA Phase II Bond Release <br />Reclaimed and Non -Mined Lands Sediment Analysis report ("sediment report" hereafter) was an <br />anonymously authored report. The response letter dated December 31, 2015 by EFCI gave the <br />impression that Mr. Allen S. Weaver was the author since Mr. Weaver signed the response letter. <br />We now know this third version was the product of Mr. Kent Gorham of Gorham Energy <br />Consultants, LLC. Since Mr. Gorham is the author and was described as a staff expert of surface <br />water modeling for both operational and bond release purpose we request that his CV be <br />included with this sediment report. We also request that employment dates be included when he <br />was an employee with DRMS, when he was a contractor with DRMS, and when he was <br />employed as a Consultant for EFCI. <br />The sediment report failed in all aspects as did the recent revision, which is basically identical to <br />the original, with the exception of a few typo corrections and a two and a half page Addendum <br />(1/8/2016) in the most recent version (January 13, 2016). However, the current method <br />displayed with the RUSLE model demonstration, the great amount of sediment that has filled <br />Pond 5 over a period of less than 5 years and the obvious sediment deposition and erosion of <br />County Road 92 near the green gate clearly demonstrates there are areas within the permit <br />boundary (reclaimed, non -mined, or other land) that are generating and transporting a great <br />