REP50242

• Permit No: C1981014
• IBM Index Class Name: Report
• Doc Date: 9/9/2004
• Doc Name: 2003 ARR Seeding Memo
• From: Janet Binns
• To: Kent Gorham, Dan Hernandez
• Permit Index Doc Type: Annual Reclamation Report
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman S[., Room 215 C O L D RA D O
Denver, Colorado 80203 D I v 1 5 1 o N D r
Phone: [phone] IVI I hI & '~ L 5

FAX: [phone] G E O L O G Y
Date: September 9, 2004 RECLAMATION•M WING
SAFETY•SCIENCE
To: Kent Gorham Bill Owens
Dan Hernandez eovernnr
Russell George
From: Janet BinnS / Executive Director
Ronald W Canany

Re: C
Southfield 2003 eedin¢ Division Director
Natural Resnnrce rrostee
I have reviewed and compared the 2003 seed tags for seeding conducted at the Southfield mine to the
approved seed mix in the Southfield Mine permit. The seed mix shown on Table 33 is the approved seed
mix for use on the Corley property. Table 33 was last revised in March 2003 during MR-48, and
approved by the Division on May 19, 2003. Based on the date recorded on the seed tags, 2003 seeding at
the Southfield Mine occurred in October 2003. Seeding occurred after Table 33 seed mix was approved.
Two perennial grass species were left out of the seed mix used in 2003 on the Corley property. These two
species were Indian ricegrass (Anchnalheram hymenoides) and Beardless bluebunch wheatgrass
(Pseudoroegneria spicata). Both species are considered native species. Based on number of seeds per
square foot, Indian ricegrass comprises 3.97% of the approved seed mix, while Beardless bluebunch
wheatgrass makes up 9.92% of the approved seed mix (13.9% combined).
Based upon the seed tags provided by Energy Fuels, two unapproved grass species were included in the
seed mix in lieu of Indian ricegrass and Beardless bluebunch wheatgrass. The two substituted species
were Crested wheatgrass var. hycrest and Intermediate wheatgrass var. Oahe. These two species are
Introduced perennial grasses and have proven to be very aggressive and persistent based upon the DMG's
more than twenty years of experience of observation of reclaimed mined lands. These two species were
not approved for inclusion in this seed mix. Crested wheatgrass comprises 10.9% of the 2003 seeded mix
on a number of seeds per square foot basis. Intermediate wheatgrass contributed 5.63% of the 2003
seeded mix on a number of seeds per square foot basis. Together these two introduced grass species
compl•ise 16.5% of the number of seeds per square foot applied on the Corley property in October 2003.
Due to the variability between size and weight of seeds depending upon the species, I felt comparison of
the number of seeds per square foot by species which comprise the total seed mix provides a better picture
of the variance to the approved seed mix made by Energy Fuels. The operator apparently seeded three
times the quantity of blue grama than in the approved seed mix, roughly twice the amount of Western
wheatgrass, and approximately half the approved amount of Cicer milkvetch on a seeds per square foot
basis than that approved in Table 33 seed mix. The overall seeding rate on the Corley property was
higher than that shown in the approved seed mix. The approved seed mix allows for doubling of the
seeding rates should seeding application use broadcast instead of drill methods. Energy Fuels divides the
seed mix into two parts, larger seeds that are drill seeded and a "fluffy" mix. It is not stated in the permit
text or in the 2003 Annual Reclamation Report whether or not the "fluffy" mix was broadcast. If it was
indeed broadcast, all the seeding rates for the seeds included in the "fluffy" mix should have been
doubled. Only Sideoats grama and Blue grama appear to have been significantly increased.
Office of Office of Colorado
Mined Land Reclamation Active and Inactive Mines Geological Survey