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iiiiiiiiiiiiiiuiii MINED LAND RECLAMATION DIVISION Department of Natural Resources 1373 Sherman St., Roam 215 Denver, CO 80203 303 866-3567 Fa x. 303 832-8106 STATE OF COLORADO pF COO 4:_' R R - N: ; Sao .•~ o ' la 76 ' Roy Romer. Governor Fretl R. Banta. Orvision Director DATE: September 19, 1990 T0: Fred Banta ~ / • ~%.: .• .~ FROM: Dan Mathews RE: GEC Pursuant to the questions raised by meeting with Chips and in his lette summarize the GEC situation below. Dr. W. D. Corley in our September 4 r of September 17, I have attempted to As you are aware, Energy Fuels Corporation (EFC) has submitted a technical revision application which outlines a plan for EFC to permit the GEC East Pit as a coal waste disposal area and assume reclamation liability for that pit. Obviously, we would like to see this happen, since this would free up the forfeited bond funds for use in reclaiming other areas, including the Orphan Pit and tipple area, Chen's Hill and Center Ridge. Two adequacy letters have been sent to Energy Fuels in regard to the TR, the first dated August 13 and the second dated August 31 (both letters are attached). The second letter was sent out following a site visit on August 29. EFC has not as yet submitted responses to the adequacy concerns and has requested that the decision deadline for the TR be extended to December 1, 1990. EFC's reason for requesting the extension is that they are currently pursuing a permit revision to incorporate additional coal leases into their' permit area, and they consider the permit revision to be a higher priority than the East Pit TR. We have approved EFC's extension request and requested that they respond to the adequacy concerns no later than Uovember 16, 1990. Dr. Corley has indicated that he would like to see us initiate bond forfeiture reclamation on areas other than the East Pit as soon as possible, rather than waiting for EFC to permit the East Pit (or, perhaps, decide not to permit the East Pit). We do not wish to do this, because the East Pit highwall presents a significant safety hazard and is our number one reclamation priority at GEC. Reclamation of the East Pit would consume all of the available bond monies in the event that the Pit is not permitted and bonded by EFC. If we initiate lower priority reclamation at this time, we would be unable to satisfactorily reclaim the East Pit if EFC ultimately chooses not to permit the site. We feel that the potential benefit to be gained by extending the EFC revision decision until December 1 is substantial. It will potentially allow us to ensure full reclamation of the East Pit, as well as reclamation of the Orphan Pit and tipple, Chen's Hill and Center Ridge.