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ACZ ACZ Inc. <br />Engineering and Environmental Services <br />1475 Pine Grove Road, Suite 109 <br />P.O. Boz 774018 <br />Steamboat Springs, Colorado 80477 <br />303-879-6260 <br />August 9, 1993 <br />Ill Illlllllllllllll <br />~^ <br />AUG 11 1993 <br />Divisionpof Miner is and Geology Divicien o, n,~i~ic ,7 ` ~ Uyc "y` <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Energy Fuels Mining Company - Raton Creek Mine (Per.~r:it C-82-055), NOV C-93-087 <br />Dear Mr Dudash: <br />The Division of Minerals and Geology (DMG) issued a Notice of Violation (NOV) for the areas <br />designated as Santa Fe Loadouts 1 and 2 under the Raton Creek Mine Permit for: <br />Failure to pass surface drainage from disturbed areas through a sedimentation pond, a series <br />of sedimentation ponds, or a treatment facility before leaving the permit area." <br />The required remedial action to abate the NOV included installation of approved sediment <br />control structures and the following related anions: <br />Submit new designs for sediment control that a) captures all srtrface drainage and treau it <br />prior to leaving the permit area, or b) retains it on site within anon-discharging facility" <br />Implement new designs within IS days following 7R approval" <br />In response to the NOV, Energy Fuels Mining Company (EFMC) inspened the site and <br />reviewed bo[h existing site conditions and those portions of the approved permit document <br />relating to drainage and sediment control plans for the loadout areas. The approved permit <br />documen[ indicates that containment berms will be established, where necessary, along the <br />permit boundary to control drainage and prevent runoff discharge from leaving the disturbed <br />area. <br />In lieu of developing designs for and construtting additional drainage structures, EFMC proposes <br />to cons[rutt containment berms in accordance with the approved drainage and sediment control <br />plan. Given the existing site conditions of uniformly flat surfaces combined with asemi-arid <br />climate, the containment berms should effenively control site drainage while avoiding significant <br />additional work and the associated surface disturbance. The berms will be constructed <br />approximately 1.5 feet high, where necessary (based on any surface gradient which would tend <br />to promote positive drainage), along the perimeter of both loadout sites. The proposed berms <br />will serve to control ninon from any upgradient undisturbed areas and to intercept and direr <br />any runoff to the existing sumps. <br />Reclamation of both loadout sites will include regrading to contain all surface runoff on-site so <br />that the berms can be eliminated. <br />