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~. ~ •• • M • !~ 1 Page two Letter to Dlr. Fred R. Banta Re: Permit 76-16/Pit 3 Surety Release September 17, 1980 The Colorado Mined Land Reclamation Act of 1976 and its implementing regulations issued in May, 1977 con- tained no specific standards regarding release of surety. EFC has thus elected to include here information supporting its request for final surety release based in part upon the standards established by the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining, September, 1980, Rule 4.15.8, and the Office of Surface Mining draft guideline entitled, "A Statistical Evaluation of Revegeta- tion Success". These standards are used solely to demonstrate that EFC has in fact exceeded any requirements for re- clamation success and completion under the 1976 Act, by satisfying standards under the newer and more detailed regulations promulgated under the 1979 Act. EFC reiterates, however, that the 1976 Act governs the question of surety release on the tracts described in this request. On the enclosed map entitled "Energy Fuels Mine #3 - Bond Release Map" each of the seven areas requested for bond release are identified with a tract identification let- ter, date of seeding and acreage amount. Each of the sep- arate tracts is discussed and the success of reclamation efforts is quantitatively documented. A detailed summary of the reclamation requirements existing at EFC Mine #3 at the time of mining and reclamation in 1974 were discussed in a previous surety release application submitted to the Board on January 5, 1978, which request was approved shortly after submission. Also, this surety release information was re- submitted on January 14, 1980, in connection with EFC Mine $1 Permit 79-177. Copies of the January 5 and 14, 1980, cor- respondence are enclosed and incorporated here by reference. Description of Reclamation Diethods Tract A: This reclamation tract was created in 1975 and 1976 from excess spoil removed from the steep hillside corresponding to reclamation tracts B and C. _T.he_excess spoil was deposited_in_the drainage along Fish Creek. The site was regraded in the spring of 1976. Topsoil that was removed from the excess spoil area, and from the area where coal was extracted was applied to the recontoured spoil in the summer of 1976. Preparation for reseeding commenced in the fall of 1976 and consisted of disking. The area was drill seeded using a rangeland drill in October of 1976 with the following seed mixture: ...:: ~. y.. „