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Mr. Allen Weaver, Mine Engineer -3- March 30, 1994 <br />Energy Fuels Mining Company <br />Rule 4.06.2(4)(a) continues with a description of the analyses required for the <br />determination of suitable topsoil substitutions. <br />Please submit the results from the physical and chemical analyses required by <br />Rule 4.06.2(41(al(i1 and 4.06.5 to demonstrate that the existing soil medium is <br />suitable for revegetation in accordance with the approved reclamation plan and to <br />support the post mining land use. As required by Rule 4.06.5, such soil tests and <br />any soil reconditioning shown to be required by the soil tests, must be accomplished <br />prior to seeding. <br />Mining related structures not previously approved as permanent structures but <br />requested by the landowner to remain as permanent structures. <br />Mining related structures previously approved as permanent structures include: <br />Starkville Gulch permanent stream channel diversion, including the 675-foot-long, <br />8-foot culvert; <br />b. Mine access road -formally the haul road; <br />c. Sediment Pond and its associated light use road; <br />d. Mine Shop building; and <br />e. Ditches installed above the refuse facility as stated on page 483, Revised <br />4113/90, of the permit. <br />During our meeting on February 24, 1994, one of the landowners, Mr. A.J. luppa, <br />stated his desire to also retain the two water tanks, the three concrete pads under <br />the office building and sheds adjacent to the office building, and the concrete pad <br />and walls remaining from the disassembled prep-plant/wash plant. If EFMC desires <br />to alter the approved reclamation plan to include these additional structures as <br />permanent structures, then EFMC must submit a technical revision containing <br />appropriate documentation demonstrating how these structures are compatible with <br />the approved post-mining land use. <br />One of the suggestions made on February 24, 1994, was to leave the concrete wall <br />and pad of the prep-plant intact and backfill over the structure. The Division is <br />concerned that burial of this intact structure may result in geotechnical instability of <br />the overlying slope and may impede revegetation success. The Division considers <br />burial of large intact structures to be an alteration of the approved reclamation plan <br />that would require a technical revision. The submitted TR should contain engineering <br />demonstrations certifying that burial of this intact structure would not result in any <br />geotechnical instability for the overlying slope and would not impede the success of <br />reclamation revegetation. <br />