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<~ _~';, energy fuels coal, inc soutthfield mine p. o. box 459 l 190 county road 9°_ florence, mlorado 812^ti phone (7191 784-6395 fax (719) 784-435° July 3, 2001 Industrial Permits and Enforcement Program Colorado Department of Public Health and Environment WQCD-PE-B2 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attn: Carla I.enkev Re: Report of Noncompliance Discharge Permit No. CO 0036595 Energy Fuels Coal, Inc. Dear Ms. Lenkey: During the monitoring period 4/01/01 to 6/30/01, permit limitations for total iron were exceeded at outfall OOIA as shown on the accompanying Discharge Monitoring Report. The pazameters exceeded and date of the exceedence are listed by outfall number below. Outfall Parameter(s) Exceeded Date(s) Exceeded No. OOl A Total Uon (30 Day Ave. & Daily Max.) 4/24/01 Only two discharges occurred at Outfall OOIA during the reporting period, and both were a result of stormwater runoff into the sediment pond (Pond No. I). Since the total iron in the two samples was L0.8 and 0.15 mg/I respectively, both the daily max. and 30~ay parameter limitations for total iron were exceeded. The cause of the high total iron, which occurred in the first discharge event, was likely caused by rust and corrosion in the pond discharge structure. This structure includes a 48-inch diameter emergency spillway culvert at the pond that feeds into a 305 feet long, 10 inch diameter culvert, at the end of which is the dischazge/sampling point. Due to dry weather conditions, the discharge system had been utilized only one time in the proceeding 18 months. Unfortunately, the sample was taken with the first 45 minutes of the dischazge which lasted most of the day referenced above. EFCI believes that there aze no conditions at the pond that could cause the high iron as found in the one sample. There aze no conditions in the small watershed area that feeds the pond that have changed from previous sampling periods. A review of discharge samples for the prior 5 years, a total of 15 samples, indicates total iron values (ave, min, max) of 0.82, 0.03, 3.37. These results show that the pond normally treats and discharges stormwater in compliance with the permit limitations with respect to total iron.