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_ .~ <br />energy fuels coal, inc. u ~1M~ / <br />soN~fleltl micro .post oMics box W9 . fbronCl. Wbnoo 81728. (716) 78~-8386 Jt~ ~ v GWL <br />Division of Minerals and GaW6py <br />September 11, 2002 <br />Mr. Kent Gorham -Environmental Protection Specialist II <br />Division of Minerals and Geology <br />1313 Sherman St. -Room 215 <br />Denver, CO 80203 <br />RE: Raton Creek Mine -Permit No.. C-82-055 <br />Comments re; August 29, 2002 Inspection <br />Per your letter dated- September 5,-2002 <br />Deaz Kent Gorham: <br />This letter is in response to your recent letter dated September 5, 2002. For ease of <br />reference, the responses are in numeric order respective to your three listed issues. <br />1. (Estimated-pond performance) In response to this issue, engineering at Montgomery- <br />Watson/Hazza (MWH) has been contacted and is to perform the calculations for <br />estimating the effluent concentration of settleable solids via SEDCAD models. The data <br />and respective maps will be submitted under permit renewal no. 4 (RN-04). <br />2. Concurrent to generating the data for item #1, MWH will review Rule 4.05.17 preparatory <br />for permanent retention of the pond. <br />Concerning "ditch grading" at the south access (entrance) road, it hasbeenEnergy Fuels' <br />experience that "grading", per say, of a ditch generates additional sediments from the <br />sloping/filling operation: Given that the ditch is close to the offsite, frontage highway, the <br />operator was concerned about potential lose of sediment offsite. Accordingly, a rock dam <br />(photo enclosed) was. placed down-grade from-the existing landowner's dam of tree <br />branches and debris. The Rock dam consisted of 3" x 9" angulaz rock that was keyed <br />(dug) in on both sides-and bottom of the ditch-with a backhoe. Next, sediments and gravel <br />down grade from the site were loaded/hauled and placed over the rock. If the Division <br />approves of the dam or a like technique, conceivably two more rock.dams placed up- <br />gradient from the existing dams would suffice. <br />Concerning the-straw bales at the west end of the 100 year event ditch, it was evident that <br />cattle had walked through some of the straw bales. As you and I had previously discussed, <br />cattle have been-on-all of the reclaimed. site and-have grazed down-the vegetation that had <br />renewed from the previous month's rain showers. Accordingly, due to cattle frequently <br />being on site, more straw bales are not a preference. Silt fence is.a consideration, but-given <br />