REV05242

• Permit No: C1982055
• IBM Index Class Name: Revision
• Doc Date: 1/8/1993
• Doc Name: ENERGY FUELS MINING CO RATON CREEK MINE PN C-82-055 PERMIT RENEWAL RESPONSES
• From: ACZ INC
• To: MLR
• Type & Sequence: RN2
• Media Type: D
• Archive: No

January 1993 Raton Creek Mine "Adequary Responses ~ 1
Map, (Map 19). The subject wells are outside of the Raton Creek permit area and were
never used to supply wa[er in conjunction with EFMC's permitted mining operations,
therefore, EFMC has no control over or responsibility for disposition of these wells.
EFMC plans to prepare and submit a technical revision detailing plans for modification
of the existing sedimentation pond prior to initiation of pond modification activities.
The required demonstration of hydrologic restoration will also be made at such time as
vegetative reestablishment allows.
Given applicable regulatory provisions requiring demonstration of hydrologic restoration,
the proposed pond modifications will be designed to allow the pond to continue to
function effectively as a sedimentation pond until such time as vegetative reestablishment
results in effective restoration of runoff flows and quality. It is anticipated that the shon-
term function of sedimentation pond and long-term function of stock watering pond can
be effectively combined by extending the discharge invert at the time the modifications
are made to a level corresponding to the maximum two acre-foot storage capacity,
retaining the existing emergency spillway, using the existing discharge pipe during the
liability period, and then extending the discharge invert following submittal and OMLR
approval of documentation of hydrologic restoration.
3. For Response (G)(2J of CMLRD Commenu of 4/16/92:
Energy Fuels states that the highwalls above and adjacent to the Helen portal area are pre-
SMCRA and will therefore not be reclaimetL According to Regulation 4.14.1(1~(6J, "In all
cases, the highwall shall be eliminated. " In other words, when Energy Fuels acquired Permit
No. C-82-055, the company became liable for reclaiming all highwalls within the permit area,
whether these highwalls were re-affected by Energy Fuels or not. Hgghwalls to be reclaimed
by Energy Fuels, therefore, include those arortnd the Helen portal area, the Animas portal
area, the highwall behind the prep plant and warehouse area, and any other in the permit
area.
The permit contains several plans for reclamation. The most comprehensive reclamation plan
deals with the elimination of a highwall. 7be worn case scenario reclamation plan doem't
specifically mention highwalls but rather only the Animas and Helen portal areas. Please
submit a reclamation plan that includes the elimination of all highwalls in the permit area,
and include any appropriate maps, cross sections and exhlbiu.
For your information, 1 have enclosed a copy of the Division's proposed revision ojcurrent
highwall regulations. This is only a proposal, and as such might not be implemented. /f there
is any action, it could rake approximately a year before it, or another version, becomes a
regrelation. Given the current statutory time frames for a review of the permit renewal, the
Division requires that your present permit renewal comply with current regulations, which
include elimination of all highwalls. Energy Fuels may submit a revision to the permit in
the f rtrsre, after any new highwall regulations go into effect, to re-address the sitruttion.
Response: The existing approved permit and related approved bonding scenario (worst
case condition, ie: total reserve is not mined out due to economic constraints and level
of refuse pile does not reach elevation of Helen portal bench) reflex partial backfilling
of Helen portal using approximately 30,000 cY of refuse material from the northern
A:~P56RFSP.LTR
01/OS/9J tpm ACZ Inc. " P.O. Bos 774018 * Ste~mboar Springs, Colorado 80477 • (303J 879-6260