2012-06-04_REVISION - C1981014 (2)

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shows that all of the "pre- permit `baseline' vegetation types" have been added to this map. Therefore, a copy of the information requested by the CDRMS is already in their files. Concern: 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? Response: Why is the Division changing past policy practice for TR -39? EFCI finds this request contrary with the Division's regulations in Rule 4.15.1(4) which states that interim reclamation monitoring "need not meet statistical adequacy requirements but shall represent the revegetation area" as well as the discussion found on page 24 of the Vegetation Guideline which states that during interim revegetation monitoring "a minimum of 10 samples should be taken with the individual seeded stands." Since the regulations and Vegetation Guideline so clearly state interim reclamation monitoring is to be performed only on "the revegetation area" and on "the individual seeded stands" EFCI would like to know why the CDRMS is asking for this information. In virtually every one of the previous revegetation monitoring efforts, examination of the individual reports reveals that the CDRMS was consulted prior to commencing every single revegetation monitoring effort and not once did they suggest that reference area sampling be completed concurrently with the interim revegetation monitoring efforts. EFCI requests that the CDRMS provide an written explanation as to why their long established interpretation of their regulations and policy statements have never required this level of detail and now they are requesting that this information must be provided to the CDRMS as a part of TR39. Concern: 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." Map14 -Mine Area Soils, shows the entire portal area as "Dumps and Pits" with the surrounding undisturbed areas mapped as soil unit 121: Ustic Torriorthents - Sedillo Complex. Map 16 -Mine Area Vegetation shows that much of the PPJ (Ponderosa- Pinyon- Juniper Woodland) vegetation complex mapping unit roughly corresponds with 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. 3