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Land Use and Vegetation Requirements of the Colorado Mined Land Reclamation Boazd" , <br />"Areas disturbed prior to August 3, 1977 which have been in continual use by the <br />mining operation (such as long-term facilities and underground mine benches) are not <br />considered to be 'previously disturbed areas'. Such areas are subject to the revegetation <br />success standards of Rule 4.15.8." <br />[t is the Division's understanding that the previously disturbed facilities area at the Southfield <br />Mine was in continual use until and after Dorchester and Energy Fuels developed the Southfield <br />Mine. Therefore, reclamation of this area would be subject to the revegetation success standards <br />of Rule 4.15.8. The discussion of revegetation success determination on page 4.15-SR, and the <br />"previously disturbed area" on Map 16 should be removed from the permit. If EFCI can <br />provide evidence to document that the facilities area was abandoned prior to redisturbance by <br />Dorchester when the Southfield Mine was developed, revegetation success standards in <br />accordance with Rule 4.15.10(1) could replace the reference azea discussions in the permit. If <br />standards for previously disturbed areas are proposed, a specific vegetative cover standard will <br />need to be included in the permit, along with justification for that standard. <br />20. Page 2.05.4-26R indicates that revegetated areas will be monitored during years 3, 7, 9 and 10 <br />following seeding. Page 4.15-4 indicates these areas will be monitored during years 4, 7, 9 and <br />10 following seeding. The discrepancy should be eliminated. Monitoring during either year <br />3 or 4 would be acceptable. The requirement for monitoring during year 7 might be <br />reconsidered since the need for any reseeding should be assessed prior to the fifth year of <br />growth in order to avoid restarting the ten-yeaz liability time period. <br />21. Page 4.05.6-SR indicates that between 16 inches and four feet of soil will be replaced over the <br />refuse in the refuse pile. In conjunction with ongoing reclamation practices, and in accordance <br />with the requirements of Rule 4.10.4(5), this page should be revised to indicate that a minimum <br />of four feet of cover will be placed on the refuse pile. <br />22. Several sections of the permit indicate that an average of 6 inches of topsoil will be replaced <br />on the reclaimed mine area. Page 4.06-SR indicates that 8 inches of topsoil will be replaced <br />in the locations of ponds 3 and 4. This sentence should be deleted. <br />23. Please update all maps depicting the disturbed area boundary, so that the topsoil stockpile <br />located in the Newlin Creek Mine permit azea is shown. <br />Section VI -Bonding Summary <br />The Division currently holds a performance bond in the amount of $941,423.00. On January 10, 1997, <br />in what was initiated under the 1994 permit renewal, the Division completed an estimated reclamation <br />liability amount of $941,423.00. The Division finds that the posted performance bond is adequate to <br />ensure reclamation of the site as described in the approved reclamation plan. <br />Southficld Minc (C-81-030) April I8, 1997 <br />Midterm Rcview 9 Third Permit Tcrm <br />