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STATE OF <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />September 5, 2002 <br />George Patterson <br />Energy Fuels Mining Company <br />P.O. Box 449 <br />Florence, CO 81226 <br />RE: Additional Adequacy Review <br />Permit Renewal No 4 (RN-04) <br />Raton Creek Mine, Permit No. C-82-055 <br />Mr. Patterson: <br />DIVISION O F <br />MINERALS <br />GEOLOGY <br />RECLAMATION <br />MINlNG•SA FETY <br />Bill Owens <br />Governor <br />Greg E. Walther <br />Executive Direttor <br />Ronald W. Cattany <br />Acting Division Direttor <br />As per your letter dated June 24, 2002, the Division of Minerals and Geology extended <br />the decision deadline to August 26, 2002 for responses to issues identified during the <br />initial adequacy review regarding Permit Renewal No. 4 (RN-04) for the Raton Creek <br />Mine. At this time, the Division has not received your responses. Please consider <br />these additional issues in your responses. <br />Recently, a storm event filled the sediment pond at the mine site. This event <br />likely occurred the afternoon of July 29, 2002. Some 68 hours later, on August <br />1, 2002, the pond was observed during an inspection. The water level had <br />receded to the level of the top of the 4-inch riser and the high water mark was <br />estimated at approximately 5 feet above the riser during the peak-of the ~torrrl <br />inflow. <br />Review of the approved permit application page 358Rk indicates that 5 feet of <br />head above the riser would take approximately 60-70 hours to discharge, which <br />is in line with the observation of actual performance. This page also refers to <br />sediment estimates and required storage capacity for the 10-year storm event, <br />calculated to be 4.91 ac-ft (water and sediment combined). <br />To the best of my knowledge, this recent storm event was not sampled by <br />EFMC, nor have any other storm-related events been sampled. This is likely a <br />function of the lack of personnel on-site during these events. The CDPS <br />Industrial General Permit requires monthly visits to check for flow or discharge <br />from the pond outfall and sampling of the discharge if it is occurring. The <br />Division recognizes that the monthly visits are unlikely to coincide with pond <br />discharge, especially at a site where discharge is infrequent. <br />