2012-06-04_REVISION - C1981014 (2)

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RESPONSE TO CDRMS SOUTHFIELD MINE C1981014 -TR39 ADEQUACY LETTER As recommended by the CDRMS, three digital scans of detailed aerial photographs of the Southfield Mine Portal area prior to permitting of this site in 1980 by Dorchester Coal were located. The first aerial photograph was obtained from the USGS website, through their Sioux Falls, SD photography office and corresponds to photograph number 2- 48- CS -VDC taken on 21 September 1954. The second, third and fourth aerial photographs were obtained from the USDA -FSA Aerial Photography Field Office located in Salt Lake City, UT. The second aerial photograph corresponds to photograph number ASCS- 1:20000 EKT -1CC -107 and was taken on 10 July 1962. The third aerial photograph corresponds to photograph number EKT- 5LL -39 and was taken on 28 August 1970. The fourth aerial photograph does not have a photo number since it was taken as a part of a digital photograph taken in August of 2009. The current limits of the Southfield Mine Portal Reclamation are based upon the limits of reclamation as obtained from using a Trimble Model GeoXH Global Positioning System using the detailed site specific topographic maps found in the Revegetation Monitoring Report found in the 2010 Southfield Mine Annual Reclamation Report. The location of the existing Portal Reference Area as well as the existing and pre - disturbance vegetation boundaries was obtained from a dwg file of Map 16 -Mine Area Vegetation supplied by Energy Fuels Coal Inc. (EFCI) of Map 16 -Mine Area Vegetation. The location of the Proposed Portal Reference Area was obtained from detailed site surveys performed using a Trimble Model GeoXH Global Positioning System when this site was sampled in the fall of 2008. In this evaluation, copies of the current reclamation boundaries, existing and proposed reference areas as well as other pertinent features were inserted into digital copies of the 1954, 1962, 1970 and 2009 aerial photographs, in order to document as closely as possible what the pre - disturbance vegetation and slope conditions were. To ensure that every concern mentioned in the CDRMS Adequacy Letter is addressed, in the following narrative, each concern will be stated in its entirety followed by our response. Concern: 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 upon aerial photos, NAIP2011, and EPA false -color infrared LandSAT 9/5/1978, it appears that a portion of the north east side of the proposed Proposed [sic] 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 exclude previously disturbed area, and adjust the data summary by removal of data collected within the excluded area. Response: As are described in the Methods Section of TR -39, "examination of this site revealed that many portions of the hillside had been disturbed by the construction of roads, and other old 1