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III IIIIIIIIIIIIIIII energy fuels mining company one tabor center • sw7e 2500 7200 seventeenth street • denver. Colorado 80202 Mr. Anthony J. Waldron Colorado Mined Land Reclamation Division 215 Centennial Building 1313 Sherman Street Denver, Colorado 80203-2273 13031623-8377 iwz 970-9372567 June 7, 1989 ~y, -- 1liFJ ! ;; i:?59 Re: Response to Stipulation 1 of Permit Renewal Approval, Suitability Evaluation of the Raton Creek Mine Refuse Cover Materials, File No. C-82-055 Dear Mr. Waldron: This letter and its attachments are being submitted in response to Stipulation 1 of the Proposed Decision for Approval of an Application for Renewal for the above referenced permit, and in response to Energy fuels Mining Company's (EFMC) commitment stated in Technical Revision No. 08. Stipulation 1 of the permit renewal approval states that EFMC must demonstrate that non-toxic refuse cover material is available in suitable quality and quantity prior to expanding the coal processing waste pile into the area above and east of the Helen Mine portals. EFMC's commitment made in Technical Revision No. 08 states that EFMC will sample and analyze both bench area and non-bench area overburden to demonstrate its suitability with respect to toxicity and combustibility as required by Rule 4.10.4(b). EFMC demonstrated in Technical Revision No. 08, that the volume of material proposed to be taken from the undisturbed areas for use in reclaiming the waste pile is adequate. By modifying the cross sections contained in Exhibit D, the areas were shown where non-toxic fill material will be recovered from bench and non-bench areas. The attached report, Suitability Evaluation of the Raton Creek Mine Refuse Cover Materials, prepared by IME, satisfies the outstanding requirements mentioned above. The methods and parameters outlined in the Division's guideline document for collection of overburden geochemistry data were utilized in the sampling. The analytical methods used in the laboratory analysis and the results are presented in Exhibit 1, Results of Laboratory Analysis, of the IME report. The attached cross sections show approximate sample site locations. This letter and its attachments have been formatted so they can be inserted as Addendum A to the approved EFMC Permit Application Package (PAP). The report functions as a stand-alone document. Minimal cross referencing to the PAP is necessary. The PAP's table of contents has been revised to include Addendum A and is included in the attachments to this letter. For reference and to facilitate placement in the PAP, all permit revision