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Fuels Eckman Park Mines and Mines 1, 2, and 3 were designed and permitted under the Interim Program <br />Regulations (prior to approval of the Colorado Program). As such, design information for these ponds may not be <br />totally consistent with the current regulatory requirements, and some surveying (elevation) errors have been <br />identified, however, unless the ponds have been modified they are "grandfathered -in", so the existing design <br />information is considered adequate. Exhibit 13 is from the Eckman Park Mine Permit (C-1981-071), and is <br />provided as historical information. Subsequent work has identified some errors and discrepancies in the <br />information provided in this table. More recent and accurate design information for Pond F is provided by <br />Exhibits 8I and 26. <br />TA2 - (a)There are inconsistent numbers for Pond F between Exhibit 8i and the pond schedule (Plate I of Exhibit <br />8p). Sediment Volume in Exhibit 8i is shown as 1.03 acre ft and on pond schedule it is listed as 13.6 acre ft. The <br />pond schedule shows the OSM height to be 7.5 ft and there doesn't appear to be an OSM height in Exhibit 8i. The <br />Total pond volume in Exhbit 8i is 2.24 acre ft and total pond volume in the pond schedule is 39.2 acre ft. The size <br />of the dewatering holes in Exhibit 8i is tin and the pond schedule shows 4 in. Please address these <br />inconsistencies. <br />Response: - The noted inconsistencies are addressed by the previous response, with Plate 1 of Exhibit 8P <br />representing historical information that has been retained for reference, but which is generally superseded by more <br />current information included in other exhibits. The Pond F design was modified by TR86-1 to address Division <br />concerns about capturing and retaining spoil spring flows. Documentation on the pond modifications is provided <br />with these responses for insertion in Exhibit 26. As a practical matter, the most recent available design <br />information for all ponds has been consolidated into a new Pond Schedule for insertion in Exhibit 8P, stickers are <br />provided for Plate 1 indicating that the historical information provided has been superseded, and the Table of <br />Contents has been updated to reflect these changes. Copies of the revised or additional materials accompany <br />these responses for insertion/replacement in the PAP. <br />40. Please check Exhibit 81 against as built specifications and stage storage exhibits for all ponds and update all <br />values in Exhibit 8P where they differ from the as built design. <br />Response: - Please refer to the previous response to Comment 39. <br />TA2 - Please update all values in Exhibit 8P where they differ from the as -built designs. <br />Response: - Please refer to the previous response to Comment 39. <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-buuilts. 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 />TA2 - Please update the Table of Contents to reflect a more accurate title for Exhibit 8Q. <br />