2015-12-15_REVISION - C1981014 - Laserfiche WebLink

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INTEROFFICE MEMORANDUM TO: ROB ZUBER FROM: JANET BINNS SUBJECT: SOUTHFIELD SL -03 REVIPW DATE: DECEMBER 15, 2015 CC: JIM STARK I have reviewed Energy Fuels Coal, Inc,'s application for a Phase III bond release for vegetation success on the Southfield Mine. The Southfield reclaimed area can be separated into two main areas; the mine and the load out. The mine is located approximately 12 miles south of the town of Florence and consists of the reclaimed portal area and associated processing facilities, reclaimed sediment ponds and processing ponds, two permanent sediment ponds, a reclaimed coal refuse pile, the reclaimed South (Monarch) vent fan, three reclaimed topsoil stockpile footprints, reclaimed rock dust tank area, a permanent ephemeral drainage diversion, a permanent truck tunnel, reclaimed explosives area, and associated light use and access roads. The second area is the reclaimed train load out, located approximately 1 mile west of the Town of Florence. The loadout consists of a reclaimed train loading area and two reclaimed sediment ponds. A two -track road runs alongside the train tracks. The train tracks and ballast remain intact and are currently owned and maintained by the Railroad. The reclaimed areas at the mine site were sampled as a unit, while the reclaimed load out was sampled independently of the mine area, in accordance with the approved permit sampling methodology. Exhibit A in SU application Tab L, illustrates the total sampling area at the mine site. Transect locations were determined randomly in accordance with the approved sampling methodology. Although ancillary areas, such as reclaimed rock dust tank, South fan, explosives area, and topsoil stockpile footprints did not have any sample transects fall in their boundaries, these areas were included in the potential sample universe as shown on Exhibit A. Vegetation sampling was conducted for total plant cover, forage productivity, and woody plant density. Species importance was derived from relative cover data collected with the total plant cover. The Division does not allow noxious species or greater than 10% relative cover to count towards reclamation success. EFCI eliminated vegetative cover attributed to annual species and state listed noxious species from both reference area and reclaimed area values. This approach is consistent with direction found in Division guidelines and is acceptable. Vegetation data was collected to statistical adequacy as defined in Rule 4.15.11(2). If sample adequacy was not achieved, a minimum of 30 samples were collected and the reverse null formula was calculated in accordance with Rule 4.15.11(2).