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\ 1 ~ ~ iii iiiiuiiiiiii iii <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparirncot n! Natural Kesuurce~ <br />I l I1 Shwomn tit., Kunm 21 5 <br />Dem•er, Colorado NUJUI <br />Phone (4U SI Hbl. 75L: <br />FAX:1}0}I H}?-H 1116 <br />November 28, 1995 <br />II~~~ <br />IIEPARTMENT OF <br />NATURAL <br />RESOURCES <br /> Nov K~~me~ <br />Mr. Randy Acre r~'~~~•'^°' <br />Energy Fuels Coal, Inc. ,.""~' z. `"`hh"•"' <br />P.O. Box 449 <br />Vu hurl H Lung <br />Florence, CO 81226 ~~~~^'~^'I~~'~"'" <br />Dear Mr. Acre: <br />Re: Southfield Mine (Permit No. C-81-014) <br />This letter is written to respond to ongoing concerns expressed by Energy Fuels Coal, Inc. (EFCI) <br />regarding the relationship between your Southfield Mine permit obligations and the GEC <br />reclamation work directed by the Division of Minerals and Geology {DMG), Inactive Mines <br />Program (IMP). It is our understanding that EFCI is concerned that GEC reclamation work may <br />negatively impact EFCI permit provision compliance. The specific areas of concern are generally <br />described below. <br />1. EFCI believes that they should not hold regulatory responsibility for the East Pit Road <br />section reconstructed during IMP-duected reclamation, which extends from the GEC entrance <br />gate to the eastern edge of the GEC East Pit. This road is currently included in the <br />Southfield permit since Southfield uses the road to access a Southfield Mine fan facility. <br />EFCI is one of at least three users of the road. <br />2. EFCI is concerned that runoff and sediment which originate on the above-referenced road <br />and uphill reclamation may enter the Southfield Mine Pond No. 5, and that such inflows have <br />the potential to jeopal'dize EFCI's ability to comply with pond maintenance requirements. <br />3. EFCI is concerned that potential erosion and sediment yield may occur on and from GEC <br />reclamation, with possible negative impacts to the Southfield Mine Magpie Creek Diversion. <br />The diversion is a permitted feature requiring maintenance and upgrade, and EFCI is <br />concerned that impacts from the GEC reclamation will cause compliance problems for EFCI. <br />We propose the following solutions to address these concerns. First, we are directing EFCI to <br />submit, as soon as possible, an Incidental Boundary Revision (technical revision) which eliminates <br />from the Southfield permit that portion of the GEC East Pit Road extending from the GEC Mine <br />entrance gate to the eastern edge of the GEC East Pit disturbance. <br />This directive is based on the recognition that the above-mentioned road segment was entirely <br />reconstructed under the direction of the DMG/IMP, and that EFCI had no control over the manner <br />