2018-07-09_REVISION - C1982056 (3)

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This site was re-evaluated. A portion of the site which could have research potential should not Needs be impacted by conveyor 5RT487 Exhibit 6T Data Yes - Avoid construction. Response: - The Permit narrative appropriately provides a summary of the cultural resource investigations and findings for specific permitting actions, referring to the cultural investigation reports for specific details. The information required by the applicable regulatory section(s) is provided in the Permit, and for any permitting action has previously been reviewed by both the CDRMS or its predecessors and the SHPO prior to approval of the related permitting action(s). Because the nature of cultural resource occurrences and related mitigation measures may vary based on extent, location, significance, and other factors, a simplified summary table, while convenient, may not provide adequate information to accurately inform the reviewer. Other than some early site- specific cultural resource recovery, documentation, and curation activities associated with undermining and rockfall from the Twentymile Sandstone cliffs, mitigation (as indicated by the above table) has generally involved controlled subsidence to limit surface impacts and/or avoidance. TA2 — Division is not asking for the data currently within the permit to be replaced by a summary table, but in addition to. As new revisions are requested by the operator, specifically proposing additional disturbance in areas already affected, it is often unclear if there are any resources in those areas and what, if any, protective measures are required. Adding a list or table to the permit which includes any known areas where protection or mitigation such as controlled subsidence and/or avoidance, would greatly speed review times of these revisions as well as give the mine a consolidated list of expectations for known sites. Please provide list or table as previously. requested. Response: - The requested table has been developed, appropriate references added, and an addition has been made to the Table of Contents — List of Tables. These revised or additional materials accompany these responses for insertion/replacement in the PAP. It is important to note, however, that SHPO policy dictates that the location of any identified cultural resource not be included in the investigation report, in order to protect the resource. Without this information, the information provided by the table is of limited value to both the operator and the CDRMS. Given this limitation, our policy and approach have been to provide our cultural resource consultant with the location and extent of any proposed surface disturbance, to include a significant buffer area when completing cultural surveys, and then to have the consultant identify any limitations or adjustments that need to be made to protect the resource. 2.05.3 Operations Plan - Permit Area Rule: 2.05.3 (4) (a) -(d) 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.I and No. 2 and Eckman Park includes a table entitled Pond Schedule. The Pond Schedule table and Exhibit 81 As Built Specification values differ from each other. Please address the following: a. Please check Exhibit 81, as built specifications for Pond F against the Pond Schedule in Exhibit 8I(P) and submit a new Pond Schedule table addressing the following values: i. Sediment Storage Volume ii. OSM Height iii. Pond Volume iv. Primary outlet size of 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, Permit C-1981-071), 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