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<br />DIVISION OF MINERALS AND GEOLOGY <br />Depatlment of Natural Resowces <br />1313 Sherman 51., Room 215 <br />Denver, Colorado 80203 <br />Phone: (3031 866-3567 <br />FA%:13031832-8106 <br />Mazch 14, 1995 <br />Mr. Allen S. Weaver <br />Energy Fuels Mining Company <br />P.O. Box 449 <br />Florence, Colorado 81226 <br />Re: Raton Creek Mines (C-82-055): Technical Revision No. 18 <br />Check Dam Designs <br />Dear Mr. Weaver: <br />II~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5. Lochhead <br />EtKUlive DireClor <br />Michael H. Long <br />Division Direclo~ <br />The Division has reviewed your revision for two check dams at the Raton Creek Mine (C- <br />82-055). The Division hydrologist has identified several concerns as follows: <br />1) The Division considers that the two structures aze check dams that impound water, <br />requiring compliance with Rule 4.05.9, "Impoundments,' but not Rule 4.05.6, <br />"Sedimentation Ponds,' except where Rule 4.05.9 refers to specific sections of Rule <br />4,05.6. The Division does not define them as sedimentation ponds because Rule <br />1,04(115) defines a sedimentation pond as a primary structure. These check dams <br />are secondary structures because they are not required to treat the disturbed area <br />runoff. There already is a primary sedimentation pond. Rule 1.04(115) further states <br />that secondary sedimentation control structures are not considered sedimentation <br />ponds. <br />The Division asserts that the two check dams impound water. First, there is about <br />1.6 to 1.8 feet of water storage capacity below the lowest culvert in the embankments, <br />making the two dams capable of impounding water. Second, it appears to that the <br />culverts are not large enough in diameter to quickly pass water out of the structure <br />without allowing a significant amount of water to back up for an extended length of <br />time. For comparison, a rock check dam would not be considered an impoundment <br />because the dam would leak like a sieve. Some water might back up behind the <br />dam, but not a lot and not for a significant amount of time. <br />For the sake of this review, the Division considered the two structures to be <br />impounding check dams and require compliance with Rule 4.05.9. <br />S r~~'I~II~II~~~~~ ~II <br />sss <br />STATE OF COLORADO <br />2. Rule 4.05.9(2) refers to Rule 4.05,6(11), and Rule 4.05.6(11)(f) requires that the <br />inslope and the outslope of the embankment add up to not steeper than 5:1 with <br />