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energy fuels coal, inc. i <br />Southfield mine • post office box 459 • florence, colorado 81226 • (719) 784 -6395 <br />February 2, 2015 RECEIVED <br />Mr. Rob Zuber — Reclamation Specialist FEB 0 5 2015 <br />Colorado Division of Reclamation Mining & Safety <br />1313 Sherman St — Room 215 Division of Reclamation, <br />Denver, CO 80203 Mining & Safety <br />RE: Technical Revision No.45 (TR -45) Request — Modify Vegetation Standards <br />Energy Fuels Coal, Inc. (EFCI) — Southfield Mine - Permit No. C -81 -014 <br />Dear Rob Zuber: <br />Revegetation success standards were established in advance for the Southfield mine as is <br />documented in the Southfield approved permit document. However, previous baseline vegetation <br />monitoring of the three original reference areas done in 1980, interim monitoring of the Refuse Pile <br />Reference Area during 1987 and baseline data collected from the Loadout Reference Area in 2008 plus <br />more recent sampling of the four currently approved Reference Areas during 2013 and 2014 in <br />connection with final bond release sampling of the reclamation of the Southfield mine and Loadout areas, <br />has documented that when the currently approved weighted averaging methodology is applied to these <br />areas, none of the four currently approved Reference Areas would satisfy the established reclamation <br />revegetation success standards for warm season species diversity. <br />A careful examination of the existing information documents, in our opinion, that the approved <br />warm season species diversity standard and shrub density revegetation success standards as recommended <br />by the Colorado Division of Wildlife in connection with Minor Revision No. 49 (MR -49), should be <br />applied to all the reclamation areas located at the Southfield mine and Loadout. Accordingly, EFCI is <br />submitting this Technical Revision request. <br />A copy of a detailed narrative and technical review prepared by Mr. Kent Crofts of I.M.E., Inc., <br />Yampa, Colorado, addressing the above issues is included with this submittal. <br />If you have questions or require further information, please contact me. <br />Sincerely, <br />rge V atterson <br />Energy Fuels Coal, Inc. <br />Enclosures: Application Form for a Revision; <br />Proposed Public Notice; <br />I.M.E.'s Technical Review; <br />Revised Replacement Pages, 2.05.4 -27 and 2.05.4 -27a <br />