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Jerry Nettleton, MCM <br />Page 12 <br />August 6, 2014 <br />d. DRMS Response #2: This item is considered resolved. <br />22. Permit page 2.05 -32c states that MCM will perform revegetation monitoring in the third year <br />following seeding. Several areas were reclaimed during the 2008 field season, making 2011 the third <br />growing season. MCM is reminded that revegetation monitoring is required for these reclaimed <br />areas this year. Please include the vegetation monitoring report with the 2011 Annual Reclamation <br />Report. <br />a. MCM Response: MCM is completing the required revegetation success monitoring in <br />conjunction with similar work for the nearby Seneca II and Yoast Mines. The resulting <br />monitoring information will be included with the 2011 Annual Reclamation Report. <br />b. DRMS Response: It does not appear MCM submitted the vegetation monitoring data <br />with the 2011 Annual Reclamation Report. However monitoring was conducted in 2011 <br />on 11.5 acres reclaimed in 2008 and submitted with the SL -3 bond release application. <br />According to the 2013 Annual Reclamation Report, final reclamation was completed on <br />17.1 acres encompassing the No. 9 Portal Area and adjacent Refuse Disposal Area in <br />May of 2009. Given the commitment discussed above, revegetation monitoring should <br />have been conducted on these areas in 2012. Please indicate if the 2012 monitoring was <br />conducted? <br />c. MCM Response #2: Due to droughty conditions, and concerns that any monitoring <br />would not be representative of normal conditions, MCM did not conduct revegetation <br />success monitoring in 2012. MCM plans to complete monitoring in 2014. <br />d. DRMS Response #2: Revised Page 2.05 -33 updates the "Vegetation Monitoring" of the <br />permit and revises the commitment to monitor revegetated areas. The revised page <br />indicates that revegetation success will typically be completed for reclaimed areas during <br />the 3rd year following final reclamation seeding and that this sampling effort will use <br />ocular estimation of cover. No discussion of herbaceous production sampling or shrub <br />density evaluation in regards to third year sampling was included in the revised page. <br />The operator should commit to sampling during the third year and remove the word <br />"typically" from the revised page, or discuss what actions would be taken if sampling <br />was not conducted during the 3rd year following reclamation seeding. Also, ocular <br />sampling is subjective and hard to quantify. The Division believes the sampling plan for <br />final revegetation success sampling should be used, however in accordance with Rule <br />4.15.1(4) sample adequacy need not be achieved for the Yd year sampling effort. Please <br />revise the proposed page accordingly. <br />23. Permit page 2.05 -33 discusses the reclamation and revegetation plan that will be used on the "No. 9 <br />Portal Area /Refuse Pile ". The No. 9 Mine refuse pile was reclaimed in 2009. Please update the text <br />on permit page 2.05 -33 to include a discussion of how the No. 9 Mine refuse pile was reclaimed. <br />