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SUMMARY AND CONCLUSIONS <br />Based upon a review of the mine permit, the applicant's bond release application, and site inspections, <br />the Division finds that Energy Fuels Coal, Inc. has completed backfilling, grading and drainage <br />reestablishment at the Southfield Mine in accordance with the approved reclamation plan. <br />TOPSOIL REPLACEMENT <br />Contemporaneous reclamation of the RDA, including topsoil replacement, commenced in 1983 and was <br />completed in 2002. At the rest of the mine site, topsoil replacement took place in 2002. At the loadout, <br />topsoil replacement for all but the two pond areas took place in 1996. Topsoil was placed on the loadout <br />ponds in 2014. <br />The average replacement thickness of topsoil in the mine facilities area and the loadout is approved to be <br />six inches (Section 2.05.4 in the PAP). For the RDA the approved thickness is one foot. Thicknesses <br />were checked in 2015 by EFCI (prior to submittal of the SL -03 application) and again during the bond <br />release inspection. Test pits were dug in 2015 at the locations shown on maps in the application; some <br />of these locations were re -checked during the inspection by the Division. <br />The results of testing indicated that depths and fertility of the topsoil are sufficient, exceeding the <br />required depths, in all areas of the mine site. <br />Loadout depths (recorded in the SL -03 application) were slightly less than 6 inches (4 to 5 inches) at <br />locations on the east side, but this is acceptable for the following reasons: <br />• Many years of settling has occurred. <br />• No significant erosion can be seen on the site. <br />• Vegetation growth is good. <br />• A check by the Division found that the topsoil is actually six inches in some areas, rather than the <br />more shallow quantities measured by EFCI. <br />The Division finds that EFCI has met the requirements for topsoil replacement. <br />REVEGETATION <br />Vegetation sampling was conducted for total plant cover, forage productivity, species diversity, and <br />woody plant density by IME (a consultant working for EFCI), with assistance from Mergen <br />Ecological Delineations, Inc. in 2013 and 2014. The reclaimed areas at the mine site were sampled <br />as one unit, and the reclaimed loadout was sampled as another unit, in accordance with the approved <br />permit sampling methodology. Appendices and maps in the SL -03 application (including the <br />Southfield Mine SL -03 Page 15 of 21 February 23, 2016 <br />