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~~. <br />~. , <br />STATE OF COLORADO RiC HAFD D. L <br />DEPARTMENT OF NATURAL RESOURCES ~V~n^ <br />Harris D. Snerman, Executive Director <br />MLNED L:~rD RECLA1ViATION <br />723 Centennial Building, 1313 Sherman Street <br />Denver, Colorado 80203 Tel. (303) 939-3567 <br />999 <br />Hamlet J. Barry, I11, <br />Director <br />M E M O R A N D U M <br />T0: KEITH KIRK, MIKE MCCARTHY <br />FROM: RICK MILLS <br />DATE: DECEMBER 26, 1979 <br />RE: ENERGY FUELS CORPORATION - ECKMAN PARK APPLICATION <br />This will serve to identify the areas that will be covered during our meetings <br />of December 27-28, 1979. The areas to be covered are: 1) bonding, 2) vegetation <br />information, 3) soils information, and 4) operation plan. The comments <br />below will be in an adequacy letter to be sent to EFC upon completion of our <br />meetings (1st week of January). Additional comments may be forthcoming as <br />a result of the meeting. These comments do not include the concerns of OSM <br />and EFC will also be responsible to respond to OSPt's comments. <br />1) Bonding - At this time the merits of EFC's bond computations can not be <br />addressed. Until the excess spoil question is resolved the costs cannot. be <br />adequately assessed. However, the bonding question can be addressed in a <br />general manner to give EFC a chance to evaluate its bonding options. EFC <br />should be aware that the state is receptive to the floating bond concept. <br />If EFC wishes to use this method of bonding, they would have to establish <br />disturbance catagories and then indicate the amount of acreage within each <br />catagory. The cost per acre between the various catagories would be signi- <br />ficant, thus allowing for a more realistic bond amount. For example, the <br />most costly catagory would be when the coal had been extracted from an area <br />and a large pit remains to be reclaimed, the other end of the spectrum would <br />be in the catagory in which seeding only has to be done to complete the <br />reclamation activities carried out by EFC. I would caelcome your comments on <br />this idea. <br />2) Vegetation Information <br />a) Section 779.19 - 1) The applicant should describe in more detail the <br />methodologies used by the various parties conducting the vegetation surveys. <br />For example, how were the quadrats choosen in the Dames and 4foore study'. <br />In the Forest Service study, hoto many transects were run, number of <br />quadrats/transect, and how the location of the transects were chosen. In <br />the BLM study, a further explanation of the methods used is required. <br />2) Table 3b - The scientific name for each species should be given, not just <br />the binomial abbreviation. The cover given in this table does not agree <br />with that given in Table 33, % vegetation cover. <br />(cont'd) <br />