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The rainfall event used in the 100-year ditch designs of the 112d Application is 2.9 <br />inches. This is conservative, since the additional 0.5 inches of rain after the first 2.4 <br />inches is completely converted to runoff (i.e., there is no soil infiltration at that point) <br />and significantly increases the peak flows compared to the 2.4-inch storm event. <br />c. The waste embankment is the primary reason for leaving_permanent ditches in <br />place after reclamation. The embankment material, however, consists of non- <br />mineralized sandstones and shales. <br />The samples of the waste material recently taken from the mine were analyzed and <br />then subjected to the synthetic precipitation leaching procedure SPLP test. The <br />analyses and test results showed that the waste rock did not contain or generate <br />elevated levels of radionuclides, metals, or other constituents of concern. These <br />results are provided in Appendix A of the 112d Application. In most cases, PMP <br />designs are only required for protecting more chemically reactive materials. <br />For the three reasons discussed above, Energy Fuels believes that the current <br />permanent ditch designs are conservative and more than adequate for site-specific <br />conditions. <br />14) As a matter of QA/QC, all construction of major features should be reviex~d on site by <br />DRMS staff prior to commencement of construction. Please commit to notifying the <br />Division in writing at least 10 working days prior to the beginning of construction of <br />stormwater control features, ore pads and proposed buildings. The Division may at its <br />discretion require apre-construction inspection and on site monitoring during the <br />actual construction. In all cases a detailed post construction report shall be required <br />within 30 days of completion of the project or prior to commencing use which ever date <br />is less <br />Energy Fuels will add language to the 112d Application committing to the above <br />notifications and inspections prior to the start of construction of the ore pad, stormwater <br />control features, and mine buildings. These construction activities will occur over a <br />period of time and will generally be scheduled between late spring and early fall when <br />weather conditions are favorable. The temporary bermed ore pad that is permitted for <br />bulk sampling purposes will be used initially to store ore until the waste pile can be <br />expanded to the north and the larger and more permanent pad installed. Drainage <br />controls will be installed in three phases over the life of the mine with the initial <br />installation of the sediment pond and associated road culverts tentatively scheduled for <br />the spring/summer of 2008. Energy Fuels plans to utilize the existing mobile trailers on <br />site that were approved for the bulk sampling program during the first few years of <br />mine operations. More permanent buildings will be installed, as necessary, once the <br />mine approaches full staffing and production. In all cases, a detailed post construction <br />report shall be submitted to DBMS within 30 days of completion. <br />L'neo~y 1~uel~ f~eso~iree5 C;c~r~oratio~~ =14 l:~dlion 13oulev~arcl. Suite EiOt) 12 <br />1~~~l~:ewvoce.. C:C:) $O 12~ C'hc7c1~: 30 f-97~-21 ~0 <br />