2011-03-30_REVISION - C1981008

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 3/30/2011
• Doc Name: Adequacy Response Review No. 2
• From: Janet Binns
• To: Marcia Talvitie
• Type & Sequence: SL12
• Email Name: JHB
• Email Name: MLT
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
TO: Marcia Talvitie
FROM: Janet Binns
DATE: March 30,
RE: New Horizon N11- e; C1981-008, SL 12 Adequacy Response Review No 2
COLORADO
D I V I S ION O F
RECLAMATION
MINING
- SAFETY
The Division received Western Fuels-Colorado's second adequacy responses on March 17, 2010. These
comments are a result of review of Western Fuels-Colorado (WF-C) response to the Division's
questions from March 9, 2011. Bond Release No. 12 (SL2) is a request for Phase II bond release on
26.8 acres of Irrigated Pasture. Bond Release No. 12 also requests Phase III bond release for 23.8 acres
of Dryland Pasture and 126.1 acres of Irrigated Pasture. I have repeated adequacy questions in italics
from my March 9, 2011 memo to you, with comments regarding WF-C's responses.
PHASE II Concerns
3.c) The May 26, 2010 DRMS letter specifically asked that a narrative statement be included
that "confirms that the vegetation established on the reclaimed area supports the
approved land use. "
The Division was unable to locate a discussion or statement of how the reclaimed area
supports the post-mining land use in the August 30, 2010 submittal. The Division
requires a discussion of how the reclaimed area supports the post-mining land uses of
Dryland Pasture and Irrigated Pasture. Have the reclaimed areas been cut for hay?
Have the pastures been grazed by domestic animals? If they have been managed
appropriately for the post-mining land use, the operator needs to describe when grazing
occurred and what the stocking rate was. (3.03.1(2)(b) and Rule 3.03.2(1)(e))
Energy Fuels-Colorado provided responses on March 18, 2011. The response
appropriately addresses this concern.
5. The. Division's May 26, 2010 letter specifically asked, "Please provide a narrative summary with
the reclamation and management history of the parcels included in the phase II release request. "
There is no discussion regarding irrigation of the Irrigated Pasture. How often was it irrigated?
How was it irrigated, flood irrigation, side roll, etc. ? Was the pasture cut? Was the hay
removed? Was the pasture grazed? If it was grazed, what were the stocking rates? Land
management involves more than just seeding and doing nothing more. The Division needs
additional information regarding how was the reclaimed irrigated pasture managed?
Office of Office of
Mined Land Reclamation Denver • Grand )unction • Durango Active and Inactive Mines