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Sampling of the plant growth media on the non-topsoiled area was conducted in 1998 with the samples sent to a lab for analysis. The 1998 Annual Reclamation Report Map did not show where the samples were collected. No one chemical parameter measured as toxic to vegetation. The analytical laboratory did provide fertilizer recommendations and rates. Fertility levels could be improved via fertilizer additions. The percent gravel in the plant growth media (spoil) material was relatively high from 22-44% of the sample. The Division sees three alternatives at this point into the liability period. Although the reclaimed vegetative communities on both the topsoiled and non- topsoiled areas aze establishing to the point that the reclamation cover success standard is being achieved, the data does not indicate that the diversity standard on the non-topsoiled area is being approached. The non-topsoiled area is dominated by one forb species. The Division suggests interseeding of approved perennial grasses and fertilizer additions as per CSU's Soil, Water and Plant Testing Laboratory's recommendation. Strip seeding of grasses into the non-topsoiled area would allow for retention of a considerable portion of the Cicer milkvetch. 2. Another alternative would be to follow the original permit commitment and import topsoil, distribute topsoil on the 17.3 non-topsoiled acres, re-seed with the approved seed mix, and apply mulch as described in the permit. 3. A third option Energy Fuels may choose to pursue would be to chance natural vegetation succession and establishment. This option has the potential of extending the liability period for meeting the approved reclamation success standards. 4. If Energy Fuels has a different option they propose for establishing the approved diversity and woody plant species on the non-topsoiled areas, please present any proposals to the Division for our review. As a part of this review, the Division requests Energy Fuels submit a map delineating where the topsoiled area and the non-topsoiled area aze. Please direct Energy Fuels to note on the map the date that all vegetation was seeded. The submitted map only defines the 1996 seeding. Please direct Energy Fuels to designate on the map where the vegetation sampling transect were located, and where the spoil samples were located. Energy Fuels needs to submit timing of weed control application and state what chemical was used. Please have Energy Fuels submit the standard deviation calculations for the submitted vegetation data. Let's get together and discuss the four options suggested above.