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To: Kent Gorham <br />From: Janet Binns <br />CC: Dan Herna e ;. an_dy xown <br />Date: August 4, 200 <br />Re: Raton Creek Mine, C-1982-055, TR-22 Adequacy response review <br />Energy Fuels submitted a reply on July 25, 2005, to The Division's adequacy letter, dated June 30, 2005. The following <br />comments respond to EFC's July 25, 2005 response letter: <br />Energy Fuels Coal, [nc. submitted revised Map "Reclamation/Pre-Disturbance Map (revised July 20, 2005). <br />Please make the following additions to this map: <br />a) Please revise the Legend Block to define: <br />i. Blue hatching. There are arrows pointing to "Disturbed Pinyon Juniper" on the map, however <br />one of the three arrows points to a white area of the map. <br />ii. What the gray shading refers to. There are red shaded areas with arrows leading to "Disturbed <br />grassland" text. Please include this definition of the red shaded areas in the legend block. <br />b) In the Map legend block there are two delineations for pre-permanent program disturbance; one listed as <br />"approximate extent of pre-law disturbance" and the other as "pre-mining Disturbance Limits". This is <br />confusing. Please make it clear on the map and in the legend block which areas are considered <br />previously mined lands in accordance with Rule 2.04.3(2) <br />2. EFC proposed a change to the reclamation success diversity standard. After discussion with the operator <br />regarding the unsuitable proposed change, the operator responded with an a-mail message proposing the <br />following reclamation success diversity standard: <br />Grasses: At least 60% of the total allowable vegetative cover with no one grass species comprising more <br />than 50 percent of the total allowable cover. <br />Forbs: At least 10 percent of the total vegetative cover. <br />As per the Guidelines, noxious species will not count towards the success standards. <br />Upon receipt of revised permit page 522, the Division finds the proposed diversity standard acceptable. Please <br />assure that EFC submit the revised permit page. <br />