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• • iiiiiiiiiiiiiiuiii~ <br />STATE OF COLC~~v ~vU <br />DIVISION OF MINERALS AND GEOLOGY <br />Dcparlmenl n( Nawral Resources <br />1713 Shaman SL, Room 215 <br />Dcnvcr. Colorado A0203 <br />Phone I7P11 Rbh-}567 <br />FAA' 01131 A32~A 106 <br />October 9, 1997 <br />Allen S. Weaver <br />Energy Fuels Coal, Inc. <br />P.O. Box 459 <br />Florence, Colorado 81226 <br />Re: Southfield Mine (C-81-014) <br />Minor Revision No. 34 <br />Midterm Review Response -Minor Edits <br />Deaz Mr. Weaver: <br />I~~~~ <br />DEPARTMEtVT OF <br />NATURAL <br />RESOURCES <br />Roy Rumcr <br />Governor <br />lames 5. Loi.hhwrl <br />Erecmive D~re~~or <br />Mii hael B Long <br />Dioi,ion Dvcuor <br />The Division has completed a preliminary adequacy review of EFCI's application for Minor Revision <br />No. 34. Based on that review, we have the following comments which are numbered in accordance with <br />the Division's midterm review document: <br />Revisions made in response to comments 1, 3, 5, 6, 7, 14, 15, and 22 were acceptable as proposed. <br />The revised pages addressed our concerns as identified in the midterm review. <br />EFCI also submitted a revised page 2.05.4-i5a which included the actual topsoil replacement <br />depth at the loadout. The currently approved page 2.05.4-15a had a replacement depth of 12"; <br />the proposed page indicates that 6" were replaced, consistent with the approved replacement <br />depth for facilities areas. Apparently the referenced 12" replacement depth was incorrect, since <br />the permit states that 6" of topsoil will be replaced on al] facilities areas. This replacement depth <br />is consistent with the soil inventory provided in the pertttit application package. <br />While reviewing these revised pages, we questioned whether topsoil is available to cover the <br />loadout azea ponds. Since there is no topsoil available for the pond sites, EFCI will need to either <br />arrange for imported topsoil, provide a demonstration that available material is a suitable plant <br />growth medium (see Section 4.06.2(4) of the Rules), or provide an augmentation plan for existing <br />materials. Please revise the permit application accordingly. <br />2l . EFCI revised page 4.06-5 so that it now states that 4' of topsoil will be placed over the refuse pile. <br />Since the 4' of cover will not be comprised entirely of topsoil, EFCI should revise the statement <br />to 4' of cover or provide the portions of the total cover that will be provided by topsoil and <br />subsoil. <br />If you have questions or aze in need of additional information, please contact me. <br />incerely, <br />usan L Burgmaier ,/ <br />Environmental Protection Specialist <br />SLB\ 1006978. W P W <br />