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Page 2 of 2 <br />July 16, 2013 <br />f) Location, number of acres, and date of planting of all previously vegetated areas: 82.1 acres. <br />2) Additional info as committed to in the permit: <br />Repairs to the subsidence holes northeast of the Thompson Ranch house need to be recorded as <br />additional backfill, topsoil and seeded acreage. EFCI provided good detail documenting the <br />mitigation work conducted at the subsidence holes. Please assure that these totals are included in the <br />totals for disturbance, backfill, topsoil replacement, and seeding. <br />The topsoil imported to the subsidence hole repair area was acceptable and did not indicate andy <br />limiting or toxic consitituents. The seed mix used was the approved Corley property seed mix (Table <br />33, Permit Page 2.05.4 -21). Seed was broadcast using double the drill seeding rate in accordance <br />with the permit. <br />In accordance with the permit commitment on page 2.05.4 -30, and Rule 4.073, and permit page <br />2.05.4 -31, EFCI is responsible for the sealing and site reclamation for all holes drilled by Dorchester <br />and Energy Fuels. Appropriate abandonment and reclamation reports, utilizing all available <br />information, will be filed with the Division for all holes that are EFCI's reclamation responsibility." <br />Please provide drill hole abandonment reports for all sealed boreholes, and conduct a field <br />reconnaissance as described on permit page 2.05.4 -30. (Rule 4.13) <br />On page 3 of the 2012 Annual Reclamation Report, EFCI states, "No additional areas were disturbed, <br />backfilled or topsoiled during the reporting period." The Division disagrees with this statement. <br />Although the subsidence holes identified in T20 S, R70W, NE 1/4 Section 25was not an intentional <br />diturbance, the Division considers this a mining related disturbance, as well as the mitigation efforts that <br />EFCI undertook to repair the holes. Please correct this statement on page 3 of the 2012 report. <br />Due to droughty conditions in 2012, EFCI decided to postpone reclamation success sampling until 2013. <br />The Division concurred with this decision. As stated in EFCI's 2012 Annual Reclamation Report (page <br />4), 2004 was the date of EFCI's last augmentation to the reclaimed area. As defined by Rule 4.15.7 (5) <br />tree and shub seedling transplants meet the definition of "planting ". Based on this information the year of <br />the last augmentive work conducted at the portal and refuse areas in 2004. Rule 4.15.7 (5) also defines <br />the limited maintenance and repair work allowed during the liability timeframe that does not re- initiate <br />the liability period. <br />Please provide to the Division a schedule of the planned reclamation of Power Substation No. 2 (Map 18, <br />T20S, R70W, NE 1/4 Section 25, on EFCI powerline). The Division considers that this structure needs to <br />be reclaimed in accordance with Rule 4.13. <br />Upon EFCI's responses and corrections to the 2012 Annual Reclamation Report, this reports shall <br />fulfillthe requirements of Rule 2.04.13. <br />Sincerely, <br />(7- <br />Janet Bums <br />Environmental Protection Specialist III <br />(303) 866 -3567 ext. 8107 <br />