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Basil Bear, Bowie Resources, LLC <br />C- 1981 -03 8 / TR -58 PAR <br />22- Apr -2014 <br />Page 3 of 4 <br />Phase III Stability Analysis — OV West Portals Design Sheets I -10 (laserfiche Permit <br />File doc date 11/10/1986; Volume 6 - Phase III Stability Analyses in the PAP <br />binders) <br />Technical Revision No. 37 (TR -37), approved October 3, 2001, addressed an apparent <br />deficiency in the drainage and sediment control plans for the West Mine bench area. <br />Sediment control for the post - grading configuration had not been contemplated at the <br />time of the PR -2 review. Under TR -37, the West Mine 1 and West Mine 2 ponds were <br />constructed to treat runoff from the regraded mine bench area. The ponds were permitted <br />as temporary structures, with Roatcap Creek reconstruction to be completed after the <br />ponds were no longer required for runoff treatment. <br />BRL should either provide the location in the approved permit application package for <br />detailed information on the proposed channel profile, plan (meander length/width), cross - <br />section, and channel lining for East Roatcap Creek, or submit a revision to provide the <br />information. <br />With respect to the 2013 Vegetation Inventory, the Division has a series of comments for which <br />no response is required. Our comments are outlined here, for your reference. <br />A. At the West Mine, 30 vegetation samples were taken for the purpose of determining the <br />contribution of suspended solids to stream flow or runoff outside the permit area in <br />excess of pre - mining levels. The samples were taken over an area that is both Phase I <br />bond release and non -bond release. While this sample distribution is adequate for the <br />purposes of this TR -58, the Division wants to clarify that the submitted data will not be <br />adequate for purposes of Phase II bond release in the area previously Phase I released in <br />SL -2 for two reasons: <br />i) ApproximateIy 10 of the 30 sample points will be redisturbed when the Roatcap <br />Creek culvert is removed and the stream channel is reconstructed anal, <br />ii) Sample adequacy will have to be demonstrated for the remaining undisturbed <br />sample points. <br />B. During the review of the vegetation data, it was noted that the State listed noxious weed <br />Cheatgrass (Anisantha tectorum) was counted as part of the annual/biennial contribution <br />for relative cover, not as a noxious weed. The Division does not allow State listed <br />noxious weeds to be Counted towards revegetation success. While it is important to count <br />noxious weeds to determine their cover contributions, they cannot contribute to any form <br />of vegetation success standard. <br />The Division re- calculated the ground cover to determine if the Phase III cover standard <br />was still achieved. To recalculate the cover value: Cheatgrass was removed from <br />annual/biennial cover, added to noxious weeds and the annual/biennial allowable cover <br />was recalculated. The result was no change in relative ground cover for the West Mine <br />and a slight reduction of .83% at the ROM area. At this time, both cover values exceed <br />