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Mr. Roy Karo <br />June 5, 2014 <br />Page 2 <br />7. The SL5 bond release application included an analysis of species diversity and composition based <br />on the incorrect 2012 Revegetation Monitoring Report, thus the results are invalid. The correct <br />2009 revegetation monitoring report did conduct sampling for species density which is used to <br />judge species diversity for the reclaimed area; however an analysis was not conducted of this <br />data. Please conduct an analysis of species diversity based on the correct revegetation monitoring <br />data and provide the Division with the results and a discussion of the analysis and revise the bond <br />release application accordingly. <br />SCC response: The SL5 application has been revised to correct the diversity and composition <br />based on the 2009 data. This response is acceptable. <br />The ponds receiving runoff from the proposed bond release area have not been approved for <br />permanent retention because SCC does not yet have the approval of the State Engineer. As part <br />of a Phase II bond release, we are required to make a finding, under Rule 3.03. l (3)(b), that the <br />areas proposed for release are not contributing suspended solids in excess of pre- mining levels or <br />adjacent non -mined areas, so that sediment control structures that are not permanent could be <br />removed. Since the ponds receiving runoff from the disturbed areas are not permanent, the <br />Division will need additional information to assist us in determining whether the area meets the <br />requirements of Rule 3.03.1(3)(b). <br />a. SCC submitted pond discharge sample data for all the ponds receiving discharge from the <br />proposed bond release area with the exception of Pond 005. Please provide the sample <br />data for Pond 005. <br />SCC provided data from Pond 005. The Division finds SCC response adequate. <br />b. SCC indicates on page 8 of the application that the receiving streams upstream of the <br />confluences have significantly higher Total Suspended Solids (TSS) than the discharge <br />from the Phase II release area. However, SCC did not cite any documentation as a basis <br />for the statement or submit sample data from the receiving streams. For the receiving <br />stream upstream of discharge points 015 and 009, please provide upstream sample data <br />for TSS. <br />SCC Response: The upstream water data would also reflect discharges from the Yoast <br />mine. SCC provided pre - Yoast data. The Division finds SCC response adequate. <br />9. The use of sediment pond discharge data to determine the level of suspended solids generated <br />from the reclaimed area is somewhat limited in that it gives information on the performance of <br />the pond in treating runoff but does not give any indication of the sediment levels coming off of <br />the reclamation. To better ascertain the levels of sediment being generated on the reclamation <br />area, the Division requested; <br />a. SCC needs to evaluate sediment levels entering the ponds receiving discharge from the <br />release area. Please submit annual sediment level survey data for each of the ponds <br />receiving runoff from the proposed release area beginning with the year each reclamation <br />parcel was seeded. <br />