ENFORCE22919

• Permit No: C1981014
• IBM Index Class Name: Enforcement
• Doc Date: 10/8/2004
• Doc Name: Memo on Seeding Rates
• From: JHB
• To: KAG TAK
• Violation No.: CV2004003
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
October 8, 2004
To:
From: Kent Gorham~To al en ch
7anet Binns
CC: Dan Hern ez
Re: Energy F Aba ment step 1
Mine
COLORADO
DIVISION O F
MINERALS
GEOLOGY
RECLAMATIO N•MINING
SAFETT•SCIENCE
Bill Owens
Governor
Russell George
E:etutive Director
for NOV CV-2004-003, Seeding Rates at Southfield Ronald W. Cottony
Division Director
Natural Resource Trustee
I have reviewed Energy Fuels submittal for compliance with Abatement Step 1 for NOV-CV-2004-
003. Energy Fuels submittal provided Number of bulk seeds per pound by species as well as
Number of Pure Live Seed per pound. Some of the PLS per pound values differ significantly from
the NRCS reference that DMG used in our September 9, 2004 review. DMG used a general
reference, NRCS Plants Database website. Energy Fuels supplied PLS seeds per pound from the
seed source, Granite Seed Company 2003-2004 catalog. Due to the variability in seed weights,
DMG accepts the bulk seed per pound values supplied by the seed company, Granite Seed.
Analyses of the Granite Seed values finds that all the seed species except for Indian Ricegrass
(Anchnatheram hymenoides) and Beardless bluebunch wheatgrass (Pseudoroegneria spicata) in
Energy Fuels Table 33 seed mix (permit page 2.05.4-21 revised March 2003 via MR-48) were
seeded at rates higher that found in the approved seedmix. Two additional species were included in
the seed mix and Indian ricegrass and Beardless bluebunch wheatgrass were not included at all in the
October 2003 seed mix.
Energy Fuels Coal, Inc. provided a statement, dated October 8, 2004, that Energy Fuels will seed the
two missing grass species into the existing 2003 reclamation stand at the approved rates no later than
October 31, 2004. Energy Fuels Coal, Inc. states that Indian ricegrass and Beardless bluebunch
wheatgrass will be hand broadcast into the 2003 seeded stand at 3.2 PLS/square foot for Indian
ricegrass and 8.0 PLS/square foot for Beardless bluebunch wheatgrass. This commitment is
accordance with the approved seed mix found on permit Table 33 (permit page 2.05.4-21 revised
Mazch 2003 via MR-48) and meets the requirements of NOV-CV-2004-003 Abatement Step No. 1.
Office of Office of Colorado
Mined Land Reclamation A[tive and Inactive Mines Geological Survey