REV103501

• Permit No: C1982055
• IBM Index Class Name: Revision
• Doc Date: 2/10/2003
• Doc Name: Response to Adequacy Review Comments
• From: Energy Fuels Mining Company
• To: DMG
• Type & Sequence: RN4
• Media Type: D
• Archive: No

ENERGY FUELS MINING COMP
February 7, 2003
Mr. Kent Gorham
Division of Minerals and Geology
1313 Sherman Street, Room 215
Denver, CO 80203-2273
[phone]
ro Box 4a~ 4,y
Florence, Colorado 81226 `~
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RE: Raton Creek Mines (PERMIT NO. C-82-055) - PR-04
Response to Adequacy Review Comments
Dear Mr. Gorham:
Enclosed please find three copies of revised and/or additional information for PR-04 addressing the
Adequacy Comments in your October 30, 20021etter. The original comment/issue and the response to
each comment are provided below.
3. Page 22 of section 2.03 incorrectly ident~er the mine ar the Southfzeld Mine. Ako, ffective dater for the DMG permit
and the NPDES permit should be updated. Please upddte section 3.03.10 (page 22) regarding other licenser and permits.
Re onse: Page 22 has been revised to correct these issues. The revised permit text is attached
Additional issuer of September S, 2002
1. The Division hat reviewed the SEDCAD+ documentation submitted in response to the question of pond performance
and water quality estimates with regard to sediment loading. Bared on these estimates, it appears that the as-built
configuration of the sediment pond !r adequate far effective sediment control and water gualily treatment. Pleare ensure
that storm discharger are sampled on an opportunistic basis. The Division will attempt to collect a sample should the
opportunity present itself during an inspection visit.
Re onse: No Response required
Why lower the emergenry spillway when the primary, 4-inch riser could be raised to hold the desired pool of water?
Lowering the emergency spillway will not achieve the purpose of storing a 1.8 acre ft pool of water without some
mad cation to the primary dinharge structure. (see next question).
Re onse.• The purpose of lowering the emergency spillway is to limit the capacity of the pond to 1.8 acre-
ft. This allows the pond to remain below the threshold of 2 acre-ft which triggers state of Colorado
permitting requirements. The purpose of the pond is not to store 1.8 acre-ft of water but is to store no
more than 1.8 acre-ft of water. The pond at the primary spillway (4-inch riser) is 0.10 acre-ft.
3. (new) Bsrle 4.05.17 requires that a permanent impoundment be renovated to the `detailed design plane for the
permanent structure" before abandoning the permit area. The Division understands that the language included on page
482R, (third paragraph from the bottom) constitutes the detailed design plan for the permanent impoundment. Please
include with this language what changer or mod~cationr will occur to the primary spillway (4-inch riser).