2011-11-30_REVISION - C1980006 ‎(2)‎

• Permit No: C1980006
• IBM Index Class Name: REVISION
• Doc Date: 11/30/2011
• Doc Name: Adequacy Review
• From: DRMS
• To: Energy Fuels Coal, Inc
• Type & Sequence: TR25
• Email Name: RDZ
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
November 30, 2011
Mr. George Patterson, General Mine Manager
Energy Fuels Coal, Inc.
P.O. Box 459
Florence, CO 81226
RE: Marr Mine (DRMS Permit C- 1980 -006), TR -25 adequacy review
Dear Mr. Patterson:
The Division has reviewed the TR -25 application from Kerr Coal Company (KCC). - TR -25 proposes to revise the
currently approved reclamation success vegetation species diversity standard. The intent of the proposed revision is to
more closely reflect the species diversity measured in the reference areas.
Among the .revisions that KCC proposes regarding the diversity standard for both the Mine area and the Loadout (aka
Tipple area) is the following:
The calculation of the species diversity values can be made using either data collected from either the first or second year
of Phase III vegetation sampling period individually, or by averaging the data from the two monitoring periods into an
average percentage relative plant cover value.
The Division is unable to accept this revision for reclamation success comparison. Rule 4.15.7(5) specifically states, "The
revegetation success criteria, as defined in relevant subsections of 4.15, shall be met for at least two of the last four years
of the liability period." . Successful species diversity is one of the relevant subsections (Rule 4.15.8(5)) requiring the
success criteria to be met for two years. KCC needs to revise this portion of the proposed success criteria to agree with
Rule 4.15.7(5).
Please address this adequacy item.
Sincerely,
Robert Zuber, P.E.
Environmental Protection Specialist
Cc: NWCC, 2580 Copper Ridge Drive, Steamboat Springs, CO 80487, attn: Nicholle Douglas
Office of
Mined Land Reclamation
STATE OF COLORADO
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
— &—
SAFETY
John W. Hickenlooper
Govemor
Mike King
Executive Director
Loretta E. Pineda
Director
Office of
Denver • Grand Junction • Durango Active and Inactive Mines