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+ • <br />GSLO55: TR-18 Mr. A. S. Wcavcr 2 <br />f <br />neither slope being steeper than 2:1. The combined slopes can be steeper than 5:1 <br />if Energy Fuels can demonstrate, through appropriate analysis, that the embankment <br />is stable. <br />Exhibit O shows that each slope is 2:1. Please flatten the slopes so that they add up <br />to S:1 and resubmit the certification, or submit demonstrations that the current slopes <br />are stable. <br />3. Rule 4.05.9(8) requires that the embankment be stabilized through vegetation or <br />other means. Energy Fuels has not stated how stabilization will be accomplished. <br />4. Rule 4.05.9(11)(c) requires that all certification reports for impoundments state the <br />storage capacity of the embankment at the time of the certification. The Energy <br />Fuels needs to provide this since water would be impounded. <br />5. Please be reminded of Rule 4.05.9(13) that requires impoundment inspections be <br />performed at least quarterly by the appropriate person, and submitted to the Division <br />annually. <br />6. The Energy Fuels states that the fill rock in the reno mattress will have a D~ of 6 <br />inches. However, Sedcad analysis shows that the Dso should be 12 inches. Please <br />justify the D~ size. Also, please be reminded that riprap should be blocky, not thin, <br />rounded rocks. <br />7. If permit page 428R is being revised in reference to the check dams, please bring the <br />section J; Topsoil Stockpiles up to current conditions to reflect that topsoil piles have <br />been used and no longer exist. <br />8. As discussed in previous telephone conversations, Map 12 needs to reflect current <br />conditions. Highwalls have been backfilled, the refuse pile has been reconfigured, <br />access roads have been regraded, topsoil piles have been utilized, and structures have <br />been removed. The certified map should reflect actual conditions (Rule 2.10.3(1)(j)). <br />The other design pazameters submitted by Energy Fuels are in agreement with the <br />Division's SEDCAD modelling. Please contact me if you have additional questions or need <br />further clarifications. <br />Sincerely, <br />~~ ~ <br />net Btnns <br />nviro ental Protection Specialist <br />c: b 2055\TR18.ASW <br />