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 Mira "Adequary Reryonsa ~ S
EFMC needs a preliminary indication from the OMLR relative to whether or not any
issues associated with the revised reclamation plan submitted in conjunction with
EFMC's S/92 Renewal Adequacy Responses can be mutually resolved through
discussions with OMLR Staff. If the OMLR indicates that this approach is feasible,
EFMC could then format and submit the revised reclamation plan and associated
responses as a technical revision for OMLR review and approval.
5. Rule 2.07.6(1J(d)(v) requires that operatoss obtain uxtivers from persons occupying dwellings
that lie within 300 feet of the permit area. A4ap I, "General Area and Property Ownership ;
indicates the proximity of certain occupted dwellings to the permit area. Please advise us as
to the location of the waivers from the owners of these dwellings.
Response: A trailer, previously located within the mine permit boundary and used as
a temporary residence, was removed from the site shortly after mining operations ceased.
The only other residences within 300 feet of the mine permit area, are owner by the
primary surface landowner, A.J. Iuppa, and his son James Iuppa. There is some question
as to whether both residences are within the 300 foot limit. EFMC will verify the
distance of both residences from the permit boundary and has contacted the Iuppa's
relative to submittal of the required waivers. Once the question of applicability is
resolved and the waivers are received from the Iuppa's, EFMC will forward copies of the
waivers along with any necessary documentation to the OMLR for insertion in the
Permit document.
6. Page 562 of the permit addresses the potential for gravity discharges from the sealed portals.
Please update Item No. 1 in this analysis, including the data that you now have concerning
mine discharge pumping ratez Also, Item No. 2 on page 562 states that the portals are not
located near the low point ojprojected mining. Please provide data showing the location of
the portals in relation to the acttra[ mine workings. Please provide an analysis of expected
water pressure fxhind the portal seals, and how the seals will resist failure under these
conditions. Finally, please address whether there are any drill holes in both of the mine
workings that can be used to monitor the flooding of the mine workingz
Response: In order to adequately respond to the OMI,R's concerns relative to potential
gravity discharge from the underground workings, EFMC is proceeding with additional
research of historical records, documentation of mine elevations relative to know water
levels and discharge points, and preliminary evaluation of the potential and magnitude
of any hydraulic head which may be established. This effort is complicated by relatively
limited mine inflow data due to low volume intermittent flows and potential hydraulic
connexions with the other abandoned mine workings which occur throughout the
permit and adjacent areas.
EFMC proposes to present and review available information with appropriate OMLR
Staff in the immediate future, and, based on this review to discuss and evaluate the best
means of identifying and mitigating any potential related concerns. Due to the
complicating faxors noted, a detailed hydrologic study may not provide sufficient
information to determine postmining hydrologic conditions with any degree of certainty.
We anticipate that other options, possibly including a general hydrologic evaluation along
with limited monitoring to verify assumptions/conclusions, may be the most practical
and effexive approach.
A:~Y56RF5 P.LTR
avosios fpm ACZ Inc. * P.O. Box 774018 * Steamboat Springs, Colorado 80477 * (303J 8796160