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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />This was a Phase II/I11 bond release inspection conducted by Kent Gorham of the Colorado <br />Division of Minerals and Geology (Division). Sandy Brown of the Division was also in <br />attendance. Albert luppa and Jim luppa, landowners, were also present during the <br />inspection and George Patterson and Rich Munson represented Energy Fuels Coal Inc <br />(EFCI). This inspection is the field inspection associated with Surety Release No. 5 (SL-05) <br />filed by Energy Fuels requesting final bond release for all areas remaining under EFCI <br />liability at the Raton Creek Mine. Ground conditions were excellent and access was good to <br />all areas. <br />The Division received a letter on September 12, 2005 from Jim luppa on behalf of himself <br />and Albert and Marilyn luppa, as landowners. In this letter, Mr. luppa detailed concerns, <br />mostly related to drainage issues, as identified during and after a recent storm event. The <br />purpose of this inspection was to evaluate Mr. luppa's concerns on-the-ground, as well as <br />evaluate the site with regard to Phase 11 and Phase III bond release criteria. This field <br />inspection is only part of the bond release process. Further evaluation of data submitted by <br />EFCI with the bond release application is necessary prior to a written findings and proposed <br />decision by the Division. Direct response to the luppa's letter will be under separate cover. <br />Availability of Records <br />The public copy of the mine records is kept at the office of the Las Animas County Clerk at <br />the county courthouse in Trinidad. All required records were easily located. Details of the <br />records inspection can be found on page 2a of this report. <br />Signs and Markers <br />Prior to the final approval of this bond release, the mine identification sign, disturbance <br />boundary markers, and permit boundary signs should be removed from the site. <br />Hydrologic Balance <br />The inspection began with a brief discussion by inspector Gorham concerning to the bond <br />release procedure as required by Rule 3.03.2. During this discussion, the Division <br />acknowledged receipt of the letter from the luppa's and suggested, in addition to field <br />inspection related to Phase II/III bond release as per the Division guideline dated April 18, <br />1995, that all parties visit each area of concern as outlined in the letter. The Division clearly <br />indicated that the first concern noted in the luppa's letter (stock ponds in canyon west of <br />mine site) was not within the jurisdiction of the Division and would not be inspected or <br />considered. These stock ponds are not part of any liability associated with the Raton Creek <br />mine disturbance and subsequent reclamation conducted by EFCI. <br />The inspection began at the location of the former surface water monitoring flume located in <br />the permanent diversion constructed by EFCI. Inspection indicated that the flume had been <br />removed. It did not appear that the minor amount of disturbed ground had been seeded or <br />mulched at this time. EFCI should seed and mulch this area in conjunction with the other <br />3 <br />