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2020-02-07_REVISION - C1994082 (9)
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2020-02-07_REVISION - C1994082 (9)
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Last modified
12/18/2024 12:37:38 PM
Creation date
2/10/2020 7:47:54 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1994082
IBM Index Class Name
Revision
Doc Date
2/7/2020
Doc Name
Adequacy Review
From
DRMS
To
Seneca Coal Company
Type & Sequence
SL7
Email Name
RAR
JLE
Media Type
D
Archive
No
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Miranda Kawcak <br /> Page 2 of 4 <br /> February 2020 <br /> for portions of the Phase II bond release parcels occurred in 2016 and sampling of the 2006 and <br /> 2010 reclaimed areas (including the haul road)were sampled in 2017. It appears that the <br /> following parcels, were seeded in 2006 or 2010 and total 20.79 acres. <br /> Yoast SL7 PHII 2006 2010 Field <br /> ID—No Yr_Seeded 1 POLY AREA POLY AREA <br /> 42006 6.538365 <br /> 17 2006 3.557198 Statistics: <br /> 97 2006 0.489755 Count: 9 <br /> 52010 3.633543 Minimum:0.489755 <br /> 60 2010 13.94308 Maximum:20.761587 <br /> 61 2010 20.060818 Sum: 77.433594 <br /> 622010 2.067332 Mean: 8.603733 <br /> 932010 6.373916 Standard Deviation:7.270485 <br /> Nulls: 0 <br /> 952010 20.761587 <br /> DRMS February 2020 <br /> 1. Please note that DRMS cannot make the finding required for Phase II bond release on <br /> the 2006 and 2010 reclaimed areas given the discrepancy in the time frames for <br /> sampling the approved reference areas and the bond release areas. The Division will <br /> withhold our approval of Phase II bond release of these parcels. <br /> Combined Phase II and III and Phase III areas <br /> DRMS also notes a discrepancy between acreage in sampling of Bond Release Block 2. The <br /> monitoring report submitted indicates sampling of 363.3 acres, while the application request <br /> comprises a total of 355.43 acres of Phase IVIII acres. DRMS's would like to know if sampling <br /> may have included areas not comprising the bond release requested area. If this is the case, <br /> DRMS cannot accept data from data points that fall outside of the SL7 bond release area. <br /> DRMS February 2020 <br /> 2. Please provide documentation that all sample points for the reclaimed areas fell within <br /> the SL7 Phase II/III and Phase III areas. Please identify the 7.87 acres that were <br /> included in the sample universe but were outside of the 355.43 acre bond release area. If <br /> sample points fell outside of the bond release area,that data cannot be used toward <br /> meeting the revegetation success criteria. <br /> Rule 4.15.7(5) Determining Reve2etation Success <br /> The above cited rule requires that final sampling for revegetation success shall not be initiated <br /> prior to year 9 of the liability period. For any Phase III and Phase II/III areas, seeding in 2007 <br /> would indicate that final sampling must occur in 2016 or later. It appears from the SL7 submittal <br /> that Phase III and Phase II/III sampling for a number of parcels seeded in 2007 were sampled in <br /> 2015. 2015 would be the eighth year of the liability period. <br />
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