2012-04-13_REVISION - C1981014

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 4/13/2012
• Doc Name: Adequacy Letter
• From: DRMS
• To: Energy Fuels Coal Inc
• Type & Sequence: TR39
• Email Name: JHB
• Email Name: DIH
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
April 13, 2012
Mr. George Patterson
Energy Fuels Coal, Inc.
Southfield Mine
Florence, CO 81226
Re: Southfield Mine, C1981014, TR39, Adequacy Letter
Proposed change to Ponderosa- Pinyon- Juniper Reference Area
Dear Mr. Patterson:
COLORADO
Q I V I S I O N O F
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pineda
Director
The Division has reviewed Energy Fuels application for a technical revision, TR39, requesting a
change to the Portal Reference Area at the Southfield Mine. The Southfield Mine is located in
the southern portion of the Canyon City Coal field and has had extensive history of mining in the
area. As a result, the Southfield Mine portal area had been disturbed prior to the Colorado
Surface Coal Mining Act and associated Regulations (effective August 30, 1980). Much of the
surrounding land had been disturbed prior to issuance of the Southfield Mine permit (previously
Dorchester No. 1), on July 30, 1984.
The Southfield permit utilized nearby undisturbed areas to establish reclamation success
reference areas. No pre- disturbance data was available for the portal area, so projections were
made using NRCS (formerly Soil Conservation Service) recommendations, adjacent area
sampling, and aerial mapping. Exhibit 11 of the Southfield permit states, "Vegetation types of
the previously disturbed mine entrance were determined on the basis of the vegetation found in
undisturbed similar topographic areas." The Portal Reference Area was established on a
northwest facing slope located southwest of the portal area. TR39 proposes to replace the
currently approved Portal Reference Area (Plot B), with a southeast facing reference area located
northwest of the Southfield portal area. Both the approved Portal Reference Area and the
Proposed Portal Reference Area are located within areas mapped as Ponderosa - Pinyon- Juniper
Woodland Complex shown on Map 16 of the permit.
After review of the proposed change to the Portal Reference Area, and evaluating landowners'
concerns with any change to determination of reclamation success, the Division has the
following questions:
1. Based on aerial photos, NAIP2011, and EPA false -color infrared LandSAT 9/5/1978, it
appears a portion of the north east side of the proposed Proposed Portal Reference Area
was previously disturbed by mining activities. Please review these aerial photos,
particularly the 1978 image, and assure that the proposed reference area does not include
any areas that had been previously disturbed by mining activities (copy of 9 -5 -1978
LandSAT photo included). Please adjust the boundaries of the proposed reference area to
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines