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produce a reclaimed site that blends well with the surrounding undisturbed areas of the <br />mesa. <br />Additional Comments <br />Most of the remainder of your letter brings up concerns that are not under the regulatory <br />jurisdiction of DRMS. I will address each briefly below. <br />Mill Facilities: Off-site mill facilities are not under the jurisdiction of DRMS. DRMS is <br />a state agency, and does not conduct NEPA type environmental analyses. <br />Transportation: Off-site transportation is not under the jurisdiction of DRMS. I have <br />been told that the increase in traffic attributable to our planned ore haulage represents less <br />than 2 percent of the existing traffic on Highway 141. Uranium ore haulage is regulated <br />by CDOT and UDOT under Title 49 of the Code of Federal Regulations for hazardous <br />materials. The Whirlwind Mine and all uranium mills require that trucking contractors be <br />in compliance with these regulations including having emergency response plans in place <br />in the event of an accident. Energy Fuels has a surface alteration permit in place with <br />Mesa County that requires Energy Fuels to assist with road maintenance on those county <br />roads that access the site, including the application of additional dust suppressant, as <br />needed, to minimize fugitive dust. <br />Cumulative Impacts: The DRMS is a state agency and does not conduct a NEPA <br />analysis nor does it consider cumulative impacts in its review of mine and reclamation <br />plans. <br />Proposed Future Operations: As stated clearly in the plan, future mining in the <br />Lumsden No. 2 and Rajah 49 will not require any surface disturbance. These mines are <br />successfully reclaimed and have been released from bonding obligations by DRMS and <br />BLM. <br />Environment: Site specific SPLP tests were conducted for ore and waste, as discussed <br />previously in this letter. An Air Pollutant Emission Notice has been submitted to the <br />Colorado Air Quality Control Division (AQCD) for fugitive dust, generator, and <br />ventilation emissions. Fugitive dust control measures will include application of <br />magnesium chloride and sprayed water to roads, pads and stockpiles plus placing covers <br />(e.g., tarps) on all ore haulage trucks. Air emissions are expected to be within state <br />standards for the area. <br />Bonding: DRMS completes a detailed bond calculation for each project using their <br />internal software. We provide our cost estimate in the application for reference. Given the <br />very low inflows of water into the mine, long-term water treatment is not indicated. <br />Temporary Cessation Limitations: Energy Fuels is not familiar with the permitting <br />details of these two mines prior to our acquisition of the property; however, we consider <br />it unlikely that there was a violation of state rules regarding temporary cessation. <br />Lr~rc~r~y 1,za<•i; l~ti~:~ri~~.-rc°~ C`c~r~~}~~s~~i~~e~ ~~ Ut~licst7 F,~~;al~~~s.t~ki. `~t~ii~.= tit}{~ 8 <br />I u~.c.E:~'~tn:a, C'O !~f)1?~ f'P~t~s~~.° ~!)~-~~i4-21'~(l <br />