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INTEROFFICE MEMORANDUM FROM: JANE"I'BIN S SUBJECT: NGW HORI ~N h ~, C-19 -008, 2003 ARR DATE: ]0/12/04 CC: DAN HGRNANDB'/. I have reviewed Western Fuels Colorado's 2003 Annual Reclamation Report. Overall, WF-C submitted a complete report. A few items were not fully reported on. I reviewed the Annual report for items specific to soil replacement and vegetation establishment activities. Please have the operator supply the requested information. This information should be included in future annual reports as well. The 2003 Annual Reclamation Report indicates that Exhibit 2003-6 provides information regarding verification of topsoil replacement thicknesses. Exhibit 2003-6 shows topsoil replacement thicknesses for areas topsoiled in 2002 or earlier. Two locations, TS60 and TS61 fell within the 467 fr. grids on the 6.71 acres topsoiled in 2003. Western Fuels-Colorado did not provide topsoil replacement thickness measurements for either of these two locations. The Division found no verification of the 2003 topsoil replacement thickness in the 2003 ARR. The required replacement thickness is found on permit page 2.OSA(2)(d)-I 1. Based on the permit commitments soils replaced in two lifts require a minimum of approximately one foot in the upper lift, lift A. Permit Exhibit 2.05.4-4 indicates that the area topsoiled in 2003 will received 2lifts. Exhibit 2.05.4-4 shows various colored fill defining distinct reclamation areas yet the map legend does not define what the different fill patterns represent. This information needs to be included on the exhibit. Based on the information submitted by Energy Fuels-Colorado, the Division cannot say if this topsoil replacement thickness was met for the 2003 reclaimed area. Ground verification of the replacement thickness should be conducted. Western Fuels-Colorado has provided analytical results of topsoil sampling conducted in 2002 and backfill (spoil) analyses conducted in 2003. No limiting parameters were identified in any of the samples; TS55, TS57, NHSS213A, NHSS213B, NHSS214A, NHSS214B, NHSS215A, NHSS215B, NHSS216A, and NHSS216B. The sample collection locations are shown on Exhibits 2003-6 and 2003.7. The 2003 ARR provided an Exhibit regazding fertilizer application to the reclaimed azeas. The report indicates the 250 Ibs of fertilizer was applied per acre. The report does not indicate what kind of fertilizer was applied at this rate. Western Fuels-Colorado needs to report what formulation of fertilizer was applied.