PERMFILE113241

• Permit No: C1981014
• IBM Index Class Name: Permit File
• Doc Date: 12/11/2001
• Doc Name: TR-12 and MR-19
• Section_Exhibit Name: EXHIBIT 15 Part 8
• Media Type: D
• Archive: No

february 1992
Tecbn~a/ Reds/on TR-12 ~ 7
INCIDENTAL BOUNDARY REVISIONS TOTALING 1.25 ACRES
On December 17 through 19, 1991, the Colorado Mined band Reclamation Division (Division) and Office of
Surface Mining, Reclamation and Enforcement (OSMRE) conducted a joint oversight inspection of the Energy
Fuels Coal, Inc (EFCI) Southfield Mine. As a result of this insspectian the Division issued a Notice of
Violation (NOV C-91-37) for "Failure to permit and bond for disturbance outside the permit azea', spedfically
referring to the pond embankments for Loadout Area Ponds 1 and 2 and Mine Area Pond 5 and the emergency
spillway for Mine Area Pond 1. This Technical Revision addresses the specific steps required to abate the
violation as outlined in the NOV and restated as follows:
• Revise all maps to include the referonced disturbance areas;
• Provide a Technical Revision documenting right of entry per Rule 2.03.6(1) and modify
portions of Exhibit 2 accordingly and 2.173-29 through 38 as necessary;
• Revise the legal description on the bond Exhibit A;
• Document bonding costs associated with the reclamation of Ponds 1, 2, 5, and Loadou[ Ponds
Ll and L2.
Specifically, this technical revision requests Division approval to incorporate a total area of approximately 1.25
acres into [he Southfield Permit area and includes associated permit [ex[, map and bonding revisions, addressing
Condition 2 for abatement of the NOV. EFCI proposes to incorporate the following areas into the Southfield
Permit area through [he mechanism of an incdental boundary revision as provided for by applicable provisions
• of Rule 2.08.4:
• Mine Area Pond 5 Embankment (OSO acres);
• Loadout Area Pond Ll Embankment (0.10 acres);
• Loadout Area Pond L2 Embankment (0.23 acres);
• Mine Area Pond 1 Emergency Spillway (0.42 acres).
The location and extent of proposed inadental boundary revision areas are shown on the Mine Plan Map, (Map
17), and the Loadou[ Area Surface and Groundwater Hydrology Map, (Map 13). These revised maps
accompany [his revision submittal for replacement in the EFCI Permit Application document and address
Condition 1 for abatement of [he NOV.
The Pond 5 embankment and Pond 1 emergency spillway are on pre-law disturbance areas previously effected
by mining operations conducted by GEC and incorporated in the GEC permit area subsequent to promulgation
of the Surface Mining Conservation and Recovery Act of 1977 and the Colorado Surface Coal Mining
Reclamation AM (1980). EFCI had no[ incorporated these areas into the Southfield Permit area due to
unresolved regulatory questions relating to pre-law activities, ongoing operations and reclamation obhgatioas
within a contiguous mine permit area. These areas have been clearly depicted in all previous permit submittals
and are reflected in the current Sou[hfeld Permit Application document. The previous submittals and current
permit document aze the basis for both the original permit approval and all subsequent renewal and mid-term
review approvals.
Prior to receipt of the NOV, the Division had informally expressed concern relative to the perceived need to
• include the Pond 5 embankment in the Southfield Perini[ area. In response to this concern, and in conjunction
with TR-11, Pond Modifications, EFCI, in a Technical Revision Adequacy Response submittal dated January
8, 1992, previously requested Division approval of an incidental boundary revision to incorporate [he Pond S
embankment in the Southfield Permit area.
ACZ lne. • P.O. Bor 77JOf8 • Steamboat Spnngr, Colorado 8Q177 • [phone]