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4 e • • III IIIIIIIIIIIII III <br />INTEROFFICE MEMORANDUM <br />TO: KENT LORI-IAM <br />FROM: JANET B <br />SUBJECT: BATON EK -82-055 <br />DATE: x/29/99 <br />CC: DAN i IERNANDEZ <br />~~V~S <br />~..~P ~-lr~~. <br />I have reviewed Energy Fuels Annual Reclamation Report and interim monitoring. The <br />interim monitoring was a permit requirement to be conducted in the third year following <br />germination. The permit states on page 519, that "monitoring shall include measurements <br />of cover, productivity, species diversity, and woody plant density." <br />The annual reclamation report complies with Rule 2.04.13(1)(x)-(f). Additional <br />information suggested by Rule 2.04.13(2) is submitted as results of the revegetation <br />establishment evaluation. <br />When the Raton Creek Mine was reclaimed in 1995 Energy Fuels was deficit topsoil. <br />Energy Fuels proposed to use all available topsoil on approximately 5.4 acres and direct <br />seed into the best available plant growth material on the remaining 17.3 acres. The <br />Division did not approve eliminating the requirement to import topsoil on the remaining <br />17.3 acres. However, the Division was willing to allow Energy Fuels to make a <br />demonstration that they could successfully re-establish vegetation without importing <br />topsoil with the caveat that Energy Fuels would conduct vegetation sampling three years <br />after germination. <br />The majority of the site was seeded in 1995 with 3.2 acres seeded in 1996. Vegetation <br />sampling was conducted in July 1998. The `'primary objective of this evaluation was to <br />compare the vegetation found on the topsoiled reclaimed areas with that found on the <br />non-topsoiled reclaimed areas." <br />The 1998 Annual Reclamation Map submitted by the operator does not show where the <br />topsoiled versus the non-topsoiled areas are. The 1998 Annual Reclamation map does <br />not show where the transect locations are distributed throughout the reclaimed area. <br />When the Division was observing the sampling in July 1998, inclusion of this <br />information was discussed with the sampling team. Please provide, on an accurate map, <br />of the locations of the sample transects. This map should also define where topsoiled <br />versus non-topsoiled areas are. None of the previous annual reclamation report maps <br />make this definition clear. Please indicate on the map that seeding was conducted in <br />1995. Only those locations seeded/re-seeded in 1996 aze designated on the submitted <br />map. <br />t. <br />