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Mr. Allen S. Weaver -3- June 17, 1994 <br />Energy Fuels Mining Company <br />J~d~i r Item Nos. 14 (a-fl addressing all other structures may be responded to in a separate <br />l~~P Z submittal delivered to the Division by August 1, 1994. <br />J <br />8.1. EFMC's responses to Item Nos. 1, 2 and 3 of the Division's April adequacy letter are <br />~~ satisfactory. <br />2. With regard to Item Nos. 4 and 10, the Division agrees that a building for the use of hay, <br /> feed and rangeland equipment storage is beneficial for rangeland use. The Division also <br /> agrees that a source of water for livestock is important. Because of this, the Division <br />/ /Q¢ ~ <br />i believes that leaving the Shop Building is appropriate for use as a storage facility and <br />that, once approved at a later date, the sediment pond would suffice as a permanent <br /> livestock watering facility. Other buildings, concrete pads and foundations, and water <br />ol` tanks should be removed. <br />~ <br />~~' The highwall located immediately north of the Shop Building would normally have to be <br /> reclaimed as. part of the reclamation plan. Additionally, because of the proximity of the <br /> Shop Building to the highwall, the Shop Building would normally have to be removed as <br /> well. To address the requirements of 4.14.1(f) of the May 24, 1994 revised Regulations, <br /> thus allowing the Shop Building to remain for rangeland use, please provide the following: <br />(a) a demonstration that the highwall behind the Shop Building was in place prior to <br />August 3, 1977; <br />(b) a demonstration that the volume of all reasonably available spoil is insufficient to <br />completely backfill the highwall so as to achieve a safety factor of 1.3; <br />(cl a demonstration that the highwall will be eliminated to the maximum extent <br />technically practical; <br />(d) a demonstration that the highwall remnant behind the Shop Building will be <br />sufficiently stable so as not to pose a hazard to the public health and safety of the <br />environment; and <br />(e) a demonstration that all exposed coal seams, toxic and acid-forming materials, and <br />combustible materials are adequately covered or treated in accordance with 4.14.3. <br />As the Shop Building is the only facility the Division believes should remain as a <br />permanent post-reclamation structure at this time, please revise the Mine Facilities List <br />(Section 2.05.3(311 accordingly. <br />~ 3. <br />~ With respect to EFMC's responses provided addressing the Division's Item No. 7 of its <br />p <br />~~ April adequacy review, no response was provided that adequately addressed <br />~~~~ Section 2.05.3(8)(a)(i)(D). Please provide this. <br />4. With respect to Item No. 8 of the Division's April adequacy review, we recommend the <br />o(~ Refuse Contour Ditch be upgraded from a 10-year, 24-hour design to a 100-year, 24-hour <br /> design, for the purpose of improving the erosion stability of the south-facing aspect of <br /> <br />(I~q~ the refuse pile and helping the reclamation vegetation become established faster. While <br />the upgrade is not strictly regulatorily required by Rules 4.10.312) and 4.09.2(7), we <br />1 <br /> <br />