2018-04-02_REVISION - C1982056 - Laserfiche WebLink

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Response: - The treatment ponds for the EMD Dewatering Facility (10 -Right) referenced in the text, with designs provided in Exhibit 8C(1), have not been built. There is, however, still the potential that they could be needed in the future, so the related text discussion and design information should be retained in the PAP. The referenced text discussion for sediment control structures has been revised to reference the applicable exhibit(s) for each structure and the design basis. Copies of the revised text pages accompany these responses for replacement in the PAP. 38. Section 2.05-76-1 regarding Pond D states that the spillway was relocated. Please either provide the exhibit number for updated as built designs for the relocated spillway, or provide a set of updated as-builts reflecting the new spillway location. Response: - The referenced Pond D spillway modifications were approved under TR07-59, with designs as shown in Exhibit 8H2. The referenced permit text has been revised to reference this exhibit and copies of the revised text page accompany these responses for replacement in the PAP. 39. Pond F Exhibit 81 includes a list of As -Built Specifications. Exhibit 8P in the Permit entitled: Plate 1, Sediment Ponds, Energy Mines No.] and No. 2 and Eckman Park includes a table entitled Pond Schedttle. The Pond Schedule table and Exhibit 81 As Built Specification values differ from each other. Please address thefollowing: a. Please check Exhibit 81, as built specifications for Pond F against the Pond Schedttle in Exhibit 8I(P) and submit a new Pond Schedttle table addressing the following values: i. Sediment Storage Volume ii. OSM Height iii. Pond Volume iv. Primary outlet size of holes b. Please submit an as built drawing of Pond F that inchtdes a general plan and cross-section of the pond that includes relevant elevations for: i. Top of structure ii. Top of standpipe iii. Dewatering holes Response: - Most of the sedimentation control structures currently used as part of the Foidel Creek Mine drainage and sediment control system were designed, permitted, and constructed for the prior surface mining operations (Energy Fuels Eckman Park Mines and Mines 1, 2, and 3), and were subsequently transferred into the Foidel Creek Mine Permit along with the associated facilities and facilities areas. It is important to note that Pond F, and all of the sedimentation structures (Ponds A through T, excluding I) associated with the Energy Fuels Eckman Park Mines and Mines 1, 2, and 3 were designed and permitted under the Interim Program Regulations (prior to approval of the Colorado Program). As such, design information for these ponds may not be totally consistent with the current regulatory requirements, however, unless the ponds have been modified they are "grandfathered - in", so the existing design information is considered adequate. Exhibit 13 is from the Eckman Park Mine Permit (C-1981-071), and is provided as historical information. Subsequent work has identified some errors and discrepancies in the information provided in this table. More recent and accurate design information for Pond F is provided by Exhibits 8I and 26. 40. Please check Exhibit 81 against as built specifications and stage storage exhibits for all ponds and update all values in Exhibit 8P where they differ from the as built design. Response: - Please refer to the previous responses to Comments 37 and 39. 41. Fish Creek Borehole Treatment Facility and associated fish creek settling ponds were modified in 2006 and 2007. Please address the following: a. Please inform DRMS if the above mentioned modifications changed anything on the ground. b. If the 2006 and 2007 modifications changed anything on the ground, please submit to DRMS updated as -built drawings.