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Response: - The referenced water treatment facility and associated ponds have been modified and upgraded over <br />time to meet changing operational needs. In 2006, the existing caustic soda (sodium hydroxide) treatment system <br />was replaced with an electro -coagulation (EC) system, approved under MR06-207. A metal building housing the <br />EC System was added, along with some piping and power -distribution modifications, and the trailer that <br />previously housed the caustic soda treatment system was removed. These changes were addressed by revised <br />permit text, changes to Map 24, and the addition of Exhibit 49G, which includes design information and <br />drawings. <br />One of two dewatering boreholes at this location collapsed and could not be recovered, so the existing inactive <br />Fish Creek Ventilation Borehole was converted to a replacement dewatering borehole. This conversion, approved <br />under MR07-216, involved installation of a pre -fabricated building and piping and power -distribution <br />modifications. These changes were addressed by revised permit text, changes to Map 24, and the inclusion of <br />additional design information and drawings in Exhibit 49G. <br />In 2016, a flocculent feed system was added to increase system efficiency and flexibility (approved under MR 16- <br />298). This system was installed within the existing EC building and required no changes to the facility. Both the <br />permit text and Exhibit 49G were revised to include information on the new system. <br />42. Exhibit 8Q is referenced in the Table of Contents as: 8Q Pond T Certification. However it provides <br />important information regarding impoundment design specifications, hydrology and soils, rather than Pond T <br />as-builts. Please address the following: <br />a. Please update the table of contents to reflect a more accurate title for Exhibit 8Q, such as for <br />example: Impoundment Design Specifications, Hydrology and Soils <br />b. Please inform DRMS what exhibit addresses Pond T stage storage and as built information. If there <br />is no such exhibit, please provide stage storage information and as built designs and cross-sections <br />for Pond T. <br />Response: - Exhibit 8Q specifically states that it is a P.E. Certification for Ponds H, E, and T, and provides <br />related information. It is important to note that Pond T, and all of the sedimentation structures (Ponds A through <br />T, excluding I) associated with the Energy Fuels Eckman Park Mines and Mines 1, 2, and 3, and subsequently <br />transferred to the Foidel Creek Mine Permit (see previous response to Comment 39) were designed and permitted <br />under the Interim Program Regulations (prior to approval of the Colorado Program). As such, design information <br />for these ponds may not be totally consistent with the current regulatory requirements, however, unless the ponds <br />have been modified they are "grandfathered -in", so the existing design information is considered adequate. <br />Exhibit 8Q does reference the Leonard Rice Consulting Water Engineers sedimentation pond design information <br />summary, (Plate 1) provided in the PAP as Exhibit 8P, which includes the basic required design information for <br />Pond T and the other remaining Mine sedimentation structures. <br />43. For the Fish Creek Tipple Pond, DRMS was unable to locate as-builts and stage -storage information. Please <br />inform DRMS what exhibit shows the cross section and stage storage information for the Fish Creek Tipple <br />Pond. If this information is not in the permit, please provide cross-section, as -built and stage -storage <br />information for the Fish Creek Tipple. <br />Response: - The Fish Creek Tipple was originally permitted as a component of the Energy No. 3 Mine. When <br />the Tipple area was added to the Foidel Creek Mine Permit, the Fish Creek Tipple permit information was <br />transferred over to Permit C-1982-056 as Volumes VII, VIII, and IX. The Fish Creek Tipple pond design <br />information is provided in Volume VII as Exhibit 8. <br />44. The 6MN Mine Water Storage Reservoir design information (Exhibit 8CC) is not called out in the Table of <br />Contents. Also, DRMS was not able to locate cross-section drawings of the reservoir. Please address the <br />following: <br />a. Please update the Table of Contents to include Exhibit 8CC and submit the updated document to <br />DRMS. <br />b. Please either: <br />i. indicate where in the permit, cross-section drawings are located for the 6MN reservoir or, <br />ii. submit cross-section drawings to DRMS. <br />