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Mr. Allen S. Weaver -4- April 18, 1994 <br />Energy Fuels Mining Company <br />over the reclaimed refuse pile. If the diversions are to be removed, please provide the <br />designs for the channels that will be reconstructed on the reclaimed slopes that will <br />convey the runoff from the natural drainages above the refuse pile in a stable manner <br />(Rule 4.05.4(4)). <br />17. Rule 4.05.2(21: This rule states, "Sedimentation ponds and treatment facilities for surface <br />drainage from the disturbed area shall be maintained until removal is authorized by the <br />Division..." Please describe how cleanings from the sediment pond and catchment basins <br />will be disposed of now that the refuse pile is to be reclaimed. <br />18. Rule 4.05.2(31: Please discuss whether the trailer SAE is planned for reclamation as part <br />of Reclamation Project 2. If so,. plans for treatment of the runoff from the reclaimed SAE <br />area should be submitted. These plans would need to be designed such that the runoff <br />from the reclaimed SAE continues to meet the applicable effluent limitations of 4.05.2 and <br />the applicable State and Federal water quality requirements for downstream receiving <br />waters. <br />19. Rule 4.05.413): If anv of the upland watershed diversions (north or south of the mine <br />area) are to be removed, please describe whether any changes to the design and/or <br />construction of the sediment pond will be needed to account for the runoff from a larger <br />contributing watershed. If so, please provide these designs. <br />20. Rule 4.05.5: Please discuss what sediment control measures will be implemented for <br />stabilizing erosion of backfilled materials (see also Item 8 in this letter). <br />21. Rule 4.06: The current proposal for topsoil redistribution is to replace approximately <br />7000 ccy of topsoil to a depth of 4.5 inches over a total area of 11.3 acres. Another <br />17.3 acres of disturbed area is proposed not to be covered with topsoil. It is stated that <br />EFMC will test the 17.3-acre-area soils for suitability, and, if indicated by test results, add <br />appropriate soil supplements to enhance revegetation success. <br />Soil productivity should be considered with regard to the approved post-mining land use. <br />As such, soil redistribution and supplementation should be proposed on the basis of the <br />physical characteristics and replacement depths necessary to produce vegetation sufficient <br />to sustain arangeland/livestock grazing use. While 4.5 inches of topsoil may be all that <br />was salvaged by previous mining operations, it will be EFMC's responsibility to ensure that <br />the soils and revegetation seed mixes used on both the refuse pile and the mine floor will <br />be suitable to produce the level of vegetation necessary to sustain the final rangeland use <br />(Rules 4.06.2(3), 4.06.2(4)(a), 4.06.5, and 4.15,1(211. <br />To this end, both the soil replacementlreconditioning plans and the revegetation seed mix <br />should be reviewed and revised to ensure that the currently approved seed mix will provide <br />revegetation sufficient to sustain the approved rangeland final use, given the possibly <br />adverse soil physical characteristics and replacement depths proposed. <br />