2017-05-04_REVISION - C1981010 (2)

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Page 5 of 8 PR8 Letter to Robin Reilley May 3, 2017 e) Soil resource information required by Rule 2.04.9 for those portions of the permit area to be disturbed by surface operations and facilities. An Order I soil survey was performed on the expanded 795.71 acres in the PR -7 permit expansion area in 2014 to satisfy the permit baseline soils sampling requirements of the CDRMS regulations. The 2014 survey identified soil mapping units based on the 2004 Soil Survey of Moffat County Area, Colorado published by the Natural Resources Conservation Service (NRCS). Previous surveys of the Trapper permit area were performed in 1972, 1979, and 1980. In 1986 the soil surveys were updated to conform to the U.S. Department of Agriculture (USDA) Moffat County soil survey in effect at that time. The earlier soil surveys used older mapping soil series numbers and nomenclature as recognized in the 1986 letter from Darrell Schroeder in Section 2.6.1.1 of the Trapper Mine permit document. Many of these older soil series could not be matched to the newer USDA soil series groups and mapping units or to the later 2004 NRCS Soil Survey of Moffat County. The original soil series descriptions from the 1972 and 1980 surveys are included in Section 2.6.1.1 to retain all relevant data from the original permit. The PR -7 area soils descriptions, based on the 2004 NRCS Soil Survey of Moffat County, have been placed in a new Section 2.6.3 of the permit document. All soils mapped and nomenclature in the 2014 survey and future surveys will align with updated soil series descriptions provided by NRCS and the Soil Survey of Moffat County. The added Section 2.6.3 also describes the soil sampling and testing, provides the results of the soil testing, evaluates the soil characteristics, and discusses soil suitability for reclamation. Section 2.6.3, describing the PR -7 2014 soil survey and testing, has been added to the permit document as page 2-345a through w and is attached to this submittal. A reference to the PR -7 Mine Expansion Area soil survey has also been added to the opening discussion of Section 2.6 on revised page 2-182. The soil survey completed in 2014 is accompanied by NRCS soil map unit descriptions included as Appendix G -VIII; field soil pedon descriptions included as Appendix G - IX to be added to Appendix G of the permit document. These added appendices are attached. Map M29A has been added to the permit document showing the soils mapping for the PR -7 expansion area and is attached herein. J) Vegetation information required by Rule 2.04.10(4) and (5). The vegetation of the PR -7 Mine Expansion Area was mapped and sampled in the fall of 2014. The mapping and sampling efforts followed baseline sampling requirements of the CDRMS Rule 2.04.10. A consultation meeting was held on April 14, 2014 to discuss the vegetation sampling with the CDRMS and agree on sampling methodologies. The results indicate that the vegetation in this area is made up predominantly of three communities: mountain shrub, big sagebrush and grassland. Much smaller acreages of aspen, wetlands, and disturbed areas (roads, home site and livestock ponds or tanks) were mapped but not evaluated in detail due to the small amount of acreage in each of these areas and the lack of projected mining disturbance. CDRMS gave pre -approval for not sampling these smaller areas as part of a consultation meeting. Plant cover, production and shrub density were calculated for each of the three major plant communities.