2014-10-06_REVISION - C1981044 - Laserfiche WebLink

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Jerry Nettleton, MCM Page 10 October 6, 2014 According to the 2013 Annual Reclamation Report, final reclamation was completed on 17.1 acres encompassing the No. 9 Portal Area and adjacent Refuse Disposal Area in May of 2009. Given the commitment discussed above, revegetation monitoring should have been conducted on these areas in 2012. Please indicate if the 2012 monitoring was conducted? c. MCM Response #2: Due to droughty conditions, and concerns that any monitoring would not be representative of normal conditions, MCM did not conduct revegetation success monitoring in 2012. MCM plans to complete monitoring in 2014. d. DRMS Response #2: Revised Page 2.05 -33 updates the "Vegetation Monitoring" of the permit and revises the commitment to monitor revegetated areas. The revised page indicates that revegetation success will typically be completed for reclaimed areas during the 3`d year following final reclamation seeding and that this sampling effort will use ocular estimation of cover. No discussion of herbaceous production sampling or shrub density evaluation in regards to third year sampling was included in the revised page. The operator should commit to sampling during the third year and remove the word "typically" from the revised page, or discuss what actions would be taken if sampling was not conducted during the 3`d year following reclamation seeding. Also, ocular sampling is subjective and hard to quantify. The Division believes the sampling plan for final revegetation success sampling should be used, however in accordance with Rule 4.15.1(4) sample adequacy need not be achieved for the 3`d year sampling effort. Please revise the proposed page accordingly. e. MCM Response #3: Although not specifically required by the applicable regulatory provisions, MCM is proposing the option of limited monitoring (ocular estimation) of reclaimed areas in year 3 to assess the progress of vegetative reestablishment. If this limited monitoring indicates poor vegetation reestablishment, there is the opportunity for reseeding the areas(s) or completing other management practices to enhance vegetative reestablishment, potentially without "restarting the clock" on the 10 -year revegetation liability period. This approach is consistent with the applicable regulatory provisions, and has been used successfully at other sites, therefore, MCM suggest that no modification of the referenced text is necessary. Note also that as a result of the 2014 revegetation success sampling effort and associated research, MCM anticipates preparing and submitting a revision to change the revegetation success criteria for certain areas to a technical standard, consistent with the approved approach for similar adjoining lands. f. DRMS Response #3: This item is resolved. Reclamation Cost Estimate;