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~r <br />III IIIIIIIIIIIII III <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmeni of Natural Resources <br />1 } 1 } Sherman 51.. Room 215 <br />Denver, CO 80_01 <br />Phone: 13031 866-3567 <br />FAX ~ (3031 812-8106 <br />September 28, 1992 <br />Mr. Allen Weaver <br />Energy Fuels Coal, Inc. <br />P.O. Box 449 <br />Florence, CO 81226 <br />Re: 1991 Annual Reclamation Report, Southfield Mine, Permit No. C-81-014 <br />Dear Mr. Weaver: <br />of cow <br />N~ -~ <br />0 <br />. w~'r1. <br />• Tr,o± <br />rB]6 <br />Rov Romer <br />Governor <br />Michael 6. Lung <br />Divisron Direnor <br />Mr. Tony Waldron has reviewed the 1991 Annual Reclamation Report for the Southfield <br />Mine. The review generated one question about the current reclamation practices at the <br />waste pile, an observation about methodology and several responses to Mr. Crofts' <br />proposals. <br />What specific measures has Energy Fuels taken to establish woody plants on the waste <br />pile? The plan on page 2.05.4-23 describes the use of transplants. The Division would <br />assume that this would be done during the initial seeding period, but does not recall any <br />seeding in early 1992. If this has not been done earlier, transplants in the 6.7 acres of the <br />10/83 reclaim area will re-start the liability time clock. <br />The 1991 data was apparently collected in mid-November of 1991, which was very late in <br />the season for data collection. During that time of the year, most, if not all, of that year's <br />growth would have been predominantly standing dead litter. It would also have been <br />somewhat difficult to separate 1991 growth and litter from 1990 growth and litter. <br />Vegetation data is usually collected during the late spring or early summer, in an attempt <br />to sample the cover at its optimum vegetative growth stage, typically during flowering. <br />Sampling during the flowering stage also helps with identification of the various <br />reclamation species. Summarily, a true estimation of vegetative cover does not appear to <br />have been obtained. <br />There are two areas where Mr. Crofts takes issue. These concern species diversity and <br />woody plant density. The success standard for species diversity at the Southfield Mine <br />has been established as when the four dominant species, based on plant cover, comprise <br />no more than 80 percent of the total species composition. No one species shall comprise <br />more than 40 percent of the total species composition, as determined by plant cover. <br />This standard was created with the understanding that the fiinal species composition would <br />probably not reflect the baseline data, given the seed mix approved. If baseline data was <br />used, one species (Blue grams) would need to account for over 50 percent of the <br />