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Page 2 of 3 <br />Regarding the request that sediment in Pond #3 be sampled before the liner in that pond is removed, Pond #3 <br />was reclaimed in 2002. According to Mr. George Patterson of Energy Fuels Coal Ins, the liner in Pond #3 was <br />disposed of off -site. We are unaware of any sediment that may have existed in Pond #3 at the time of its <br />reclamation. <br />Regarding the request that Pond #4 be left as a permanent pond, the approved reclamation plan for the <br />Southfield Mine presently requires Pond #4 to be reclaimed. We suggest you contact Energy Fuels Coal, Inc <br />regarding your request to have Pond #4 left unreclaimed, as it would be the responsibility of the company to <br />first submit to our office for our consideration a request to revise the Southfield Mine reclamation plan so as to <br />allow the pond to remain. Such a request would need to demonstrate to our satisfaction that the requirements of <br />our laws and regulations regarding sediment pond retention could be met. <br />Regarding the request that water retention tablets, supplemental watering, and fencing be used in support of <br />establishing tree seedlings, woody plants are presently required to be re- established by Energy Fuels Coal Inc. <br />Whatever techniques the company may wish to use to achieve that requirement is up to the company. The <br />Southfield permit presently states, "Protective netting or temporary fencing may be placed around the <br />transplants if EFCI anticipates wildlife or rodent damage...If seedling loss on reclaimed areas becomes a <br />significant concern, EFCI will evaluate alternative control measures, review with DRMS, and obtain approval <br />prior to implementation ". Fencing has been utilized. Should the company wish to utilize water retention tablets <br />and supplemental irrigation, these techniques would be the responsibility of Energy Fuels Coal Inc to consider. <br />You may therefore wish to contact the company in regard to your request. Should the company wish to <br />implement your suggestions, the company would need to first submit for our consideration a request to revise its <br />permit to incorporate those techniques into the company's reclamation plan. Please be aware that a significant <br />amount of irrigation might require an extension of the reclamation liability period. <br />Regarding the question as to why the valve on Pond #4's dewatering device is welded shut, the welding of Pond <br />#4's dewatering device occurred in response to the Division's February 21, 2002 Mid -Term Review of the <br />Southfield Mine permit. Item 12 of that Mid -Term Review states, "With the completion of backfilling, grading, <br />topsoil replacement and seeding, it is the Division 's understanding that no one will he on site at all times. The <br />Division recommends that Pond 4 and Pond 5 he redesigned to include a method for passively dewatering these <br />ponds. Please provide new SEDCAD demonstrations showing that these ponds are able to safely pass a 10- <br />year /24 -hour storm event. Please update maps 23 and 24 (Sediment Pond No. 4 Design and Sediment Pond No. <br />5 Design, respectively) to reflect these changes ". <br />Technical Revision TR -33 was submitted to our office on June 10, 2002 in response to the Mid -Term Review. <br />Energy Fuels Coal Inc's response to Mid -Term Review Item #12 via TR -33 was "Ponds 4 & 5 were originally <br />designed for full containment of the 10 year /24 -hour storm. The ponds were equipped with crops [corrugated <br />metal pipes] and valves for manual dewatering to the designed elevation. The ponds have been re- designed to <br />treat the 10-year/24-hour storm event. This is accomplished by eliminating the dewatering valves and adjusting <br />the inverts of the principal spillways. New design drawings for each pond and new SEDCAD4 demonstrations <br />are attached to this TR. The new information includes Map 33, Southfield Reclamation Plan, Map 34, Post <br />Regrading Sediment Pond No. 4, Map 35, Post Regrading Sediment Pond No. 5, SEDCAD4 Demonstrations for <br />Ponds 4 & 5, and text description included in Exhibit 19, new section "Post regrading Drainage and Sediment <br />Control Plan ". Technical Revision TR -33 was approved on August 10, 2002. The Division's inspection report <br />for an inspection conducted on December 5, 2002 seems to have documented the conversion of Pond 4 to a <br />passively - dewatered pond, as the report states, "Pond 4 was dry at the time of the inspection. The pond was <br />stable and well vegetated. The pond has been converted to a self - dewatering pond. The Division surveyed the <br />top of the discharge pipe and its elevation was the same as the elevation stated on the as -built map ". <br />Regarding the comment that the Pond #4 overflow apparatus is not working, DRMS inspected the mine on <br />August 24, 2012, and found Pond #4's discharge structures to be in compliance with their approved designs. <br />