2012-04-13_REVISION - C1981014 - Laserfiche WebLink

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April 13, 2012 Page 2 of 6 exclude previously disturbed area, and adjust the data summary by removal of data collected within the excluded area. 2. Please provide copies of the raw sampling data from the 2008 Proposed Reference area sampling. 3. Exhibit 11 Keenan study refers to "Permit Area Figure 1 ". The Division was unable to locate Exhibit 11- Figure 1. Since this figure shows pre- permit "baseline" vegetation types, it is pertinent to the permit record. Please provide a copy of the referenced Exhibit 11- Figure 1 if possible. 4. On page 5 of the TR39 application, IME (consultant for Energy Fuels) states, "IME has been monitoring the reclamation success of the reclaimed areas at the Southfield Mine since 1987 and through 2010 has monitored the vegetation on various areas at this site, in 1987, 1989, 1991, 1999, 2006, 2008 and in 2010." No data was provided for 2008 sampling of the approved Plot B/Portal reference area. Was the Portal Reference Area sampled during the monitoring of the reclaimed areas? Please provide data from sampling of the Portal Reference Area collected recently, i.e. from 2006 or 2008. How does the current Portal Reference Area /Plot B reference area condition compare to the 1980 data? The Division disagrees with several of the conclusions presented by Energy Fuels in the TR39 application: On page 7, the permittee makes the assertion, "in short, the soils corresponding to the Portal Reference Area do not correspond to the predominant soils associated with the soils mapping unit and represent conditions that are too atypical to be considered suitable as a reference area site." Mapl4 -Mine Area Soils, shows the entire portal area as "Dumps and Pits" with the surrounding undisturbed areas mapped as soil unit 121: Ustic Torriorthent - Sedillo Complex. Map 16- Mine Area Vegetation shows that much of the PPJ (Ponderosa- Pinyon- Juniper Woodland) vegetation complex mapping unit roughly corresponds with the soils map unit 121. Both the approved Portal Reference Area (Plot B) and the proposed Portal Reference Area are within both of these soil and vegetation mapping units. Without actual soils data, The Division does not agree that Plot B reference area is atypical of the soil or vegetation mapping units. Page 8 of TR39 application states, "The fact that this site adjoins a previously disturbed site which by their standards contains `numerous introduced species' and which also possess a pronounced bias due to their proximity to the boundary of the two different vegetation types renders this site totally unsuitable with respect to a reference area using the current regulatory standards and policies of the DRMS."