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.~ <br />STATE OF COLORADO <br /> <br />RiC HARD D. LAMM, Govmnnr <br />DEPARTMENT OF NATURAL RESOURCES <br />D. Monte Pascoe, Executive Director <br />MINED LAND RECLAMATION <br />423 Centennial Building, 1313 Sherman Sireat <br />Denver, Colorado 80203 Tel. (303) <br />III IIIIIIIIIIIII III <br />David C. Shelton <br />April 6, 1982 DI~eCtO~ <br />TO: Bob Liddle <br />FROM: David Craig (~~ <br />RE: Comments Regarding Energy Fuels No. 3 Adequacy Responses <br />Pursuant to your request, I have reviewed the geology, ground water, and <br />alluvial valley floor portions of the Energy Fuels No. 3 adequacy letter <br />response (December 29, 1981). Many of these concerns have been adequately <br />addressed by the applicant. The several exceptions are discussed below. <br />Corr¢nent #4 under the "Geology and Hydrology Description" concerns (p. 5 of <br />,~ the June 2, 1981 adequacy letter) requires that the applicant determine the <br />post-mining recharge capacity of the reclaimed spoils aquifer. This is to be <br />determined through monitor well pump tests and infiltration studies. In the <br />response, the applicant has committed to the installation and pump testing <br />of a spoils monitoring well. However, there is no mention of the infiltration <br />studies. The infiltration studies are an integral part of the determination <br />of post-mining recharge capacity. However, this information is needed only <br />to evaluate reclamation success and not as necessary baseline data. Therefore, <br />the infiltration study requirement can be added as a stipulation to the permit <br />and need not be required previous to permit issuance. <br />UJo Comment #6 of the same section requires that the hydrologic properties of the <br />"highly fractured fault zone" identified by the applicant be determined. The <br />applicant proposes both an underground and a surface mine in this permit request. <br />A final decision has not been made regarding when or if the underground mine <br />would be opened. The proposed underground operation would mine through this <br />fault zone. The proposed surface mining operations will not encounter the <br />fault. Since the fault also cuts through the Twentymile Sandstone and subcrops <br />in the alluvium of Foidel and Middle Creeks (all major aquifers), there is~ <br />the potential for material damage of ground water resources. This potential <br />has not been evaluated by the applicant. It is proposed by the applicant <br />that the submittal of this information be delayed until a final decision is <br />made as to whether or not to re-open the underground mine. The applicant has <br />committed to submit the required information no later than 90 days prior to <br />the opening of the underground mine. This issue is the primary concern <br />regarding the relationship between the proposed underground mining and the <br />Local ground water resources. Therefore, a credible statement of the "Probable <br />Hydrologic Consequences" of the underground mining cannot be developed without <br />this data. However, this has no effect on_the p~r~nced cnrfa~a m; r,; no operations <br />_since-they-do-not encounter-the-fau3-t none. The concern is only directed <br />towards the underground operations. statement of "Probable Hydrologic Con- <br />sequences" cnuld be developed for the proposed surface mine based on data <br />submitted to date. <br />cc: Dave Shelton <br />Fred Banta <br />/mt <br />