PERMFILE117745

• Permit No: C1982055
• IBM Index Class Name: Permit File
• Doc Date: 12/11/2001
• Section_Exhibit Name: ADDENDUM A SUITABILITY EVALAUATION OF THE RATON CREEK MINE REFUSE COVER MATERIALS
• Media Type: D
• Archive: No

• INTRODUCTION
During the recent permit renewal process for the Raton Creek Mines (File
No. C-82-055) the Colorado Mined Land Reclamation Division (CMLRD) stipulated
that Energy Fuels Mining Company (EFMC) collect and submit data to
demonstrate that the existing overburden materials located in the area are
suitable as required by Rule 4.10.4(b) for use as cover material for the
refuse pile reclamation plan. In order to obtain the necessary documentation
involving the suitability of these overburden materials as cover materials,
EFMC committed to sample and submit data to document the properties of these
overburden materials as discussed on page 459 of the Raton Creek Mine permit.
The purpose of this evaluation is to present the results of the data
collected and demonstrate the suitability of the refuse cover materials.
SAMPLING METHODS
In order to characterize the overburden materials at the Raton Creek
Mines all of the previously collected data on soils, and overburden were
examined. This evaluation revealed that several detailed site specific
soils, refuse and overburden characterization efforts were conducted in 1982
and 1983 by the Soil Conservation Service and consultants hired by Sundance
Coal Company, the previous owner of the mine. This evaluation revealed that
17 soils samples were analyzed for various parameters deemed to be of
importance to the Division at the time the mine was originally permitted.
These samples were collected from various undisturbed areas, previously mined
areas, and topsoil stockpiles according to Division regulations. Several of
• these samples were obtained from areas disturbed by mining activities that
occurred several years prior to sampling. The soils report for the Raton
Creek Mine also contains 45 soil profile descriptions made by the Soil
Conservation Service at the•time these areas were mapped. Although samples
for chemical analysis were not taken at each of these sites they are valuable
in providing important data on the physical properties of these soils. The
original Sundance Coal Company permit contained one refuse sample and four
roof and floor samples to characterize the overburden materials.
The existing permit information was supplemented by additional bench and
overburden data that were collected by IME of Yampa, Colorado on August 23-
25, 1988 and analyzed by ACZ Laboratory Division of Steamboat Springs to
determine the reclamation suitability of these materials. These samples were
collected from the areas identified in the currently approved reclamation
plan as the source of refuse cover material, and were obtained to get a data
set representative of all materials planned for use as refuse cover as
outlined on page 459 of the approved permit document. Specifically, sampling
of non-bench material was conducted on the hillside north of the existing
refuse disposal area. A trench was excavated with a dozer starting at the
maximum elevation of the planned extent of the cover material recovery area
and extending downhill to the existing refuse disposal area. The trench was
excavated to a depth of approximately three feet or until consolidated
bedrock was encountered. Each lithologic unit was identified and sampled
according to the Division's "Guideline for Collection of Baseline Water
Quality and Overburden Geochemistry Data" by taking a continuous slice of
material across each unit. A total of 19 distinct overburden samples were
collected, representing each lithologic unit encountered including colluvial
. materials planned for use as refuse cover. Field notes at each sample
location were taken to characterize the rock fragment content using the
procedures outlined in the National Soils Handbook (USDA 1983).
In addition, a total of five bench material samples were collected from
materials found in the Raton Creek No. 2 Mine area. The white sandstone