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Rob Zuber <br />December 31, 2015 <br />Page 3 <br />Comparing steep slopes on non -mined areas to flat slopes on the reclaimed areas (or vise versa) is of no <br />interest and invalidates any comparison. Therefore, reasonable and representative slope values selected <br />and used in the calculations for the LS factor and a resulting average slope value was used for both the <br />reclaimed and non -mined condition. <br />4. Page 3 of Appendix D has two tables with cover values, and the source of these values are the <br />vegetation data in Appendices G and H. In the table for reclaimed areas, the 2014 Vento value <br />appears to be an error: from the vegetation data, it appears this value should be 75.47, not 65.47. <br />RESPONSE: <br />The Vento reclamation cover value was corrected from 65.47 (typo) to 75.47 and the sediment <br />calculations were also corrected using the 75.47 value in the two-year average calculations for cover. <br />The RUSLE calculation for sediment yield from the reclaimed area decreased from 0.313 <br />tons/acre/year to 0.275 tons/acre/year. The conclusion that the reclaimed area produces less sediment <br />than an adjacent non -mined area remains the same as a result of this correction. The corrected cover <br />value is included in the above referenced replacement copies of the mine site sediment demonstrations. <br />5. Appendix E: On the bond release map for the mine site, the disturbance associated with the <br />Corley Mine Well is not shown as an area of interest for this application. <br />RESPONSE: <br />The application requested Phase I, 11, and III bond release for the permanent road to the Corley (Mine) <br />Well rather than, as stated, the disturbance associated with the Corley Mine Well. Both the road <br />segment to the well and the Corley Well are permanent structures. Exclusion of this road on the Mine <br />Site Bond Release Map was an omission. The segment of light -use road to the Corley Well was <br />included in the permit as mine related disturbance by approval of Minor Revision No. 47 (MR -47), this <br />revision resulting from discussions with the Division during approval of the Phase I bond release <br />request (SL -02) for the mine site. Submittal of MR -47 included a description of the road segment and <br />its associated disturbance area was shown on revised Map 12. Copies of Map 12, latest revision <br />02/2015, are included to be inserted in Appendix E of the SL -03 application. <br />6. Technical Revision 45 was approved on July 31, 2015. TR45 provided corrected surveyed <br />acreage values for the reference areas. These values are found on PAP page 2.04.10-5a. The <br />acreage values used in the 2013 and 2014 vegetation reports are not consistent with the value in <br />the PAP. Because reclamation success standards are based on an acreage -weighted approach for <br />both the reference areas and the reclaimed areas, EFCI needs to use the approved acreage as <br />shown in the permit for the reference area calculations. <br />RESPONSE: <br />Acreage values for the reference areas was corrected in text of the 2013 and 2014 vegetation reports to <br />be consistent with those values shown on approved PAP page 2.04.10-5. Replacement copies of the <br />revised text portion of the 2013 and 2014 vegetation reports are attached hereto for your review. <br />