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2020-07-06_REVISION - C1994082
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2020-07-06_REVISION - C1994082
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Last modified
7/7/2020 2:28:13 PM
Creation date
7/7/2020 1:14:56 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1994082
IBM Index Class Name
Revision
Doc Date
7/6/2020
Doc Name
Proposed Decision and Findings of Compliance
From
DRMS
To
Seneca Property LLC
Type & Sequence
SL7
Email Name
RAR
JLE
Media Type
D
Archive
No
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For SU, SPL submitted results from 172 depth samples <br />taken over 818 acres. The samples were evenly <br />distributed throughout the reclaimed area. The results <br />indicate that an average of 1. 8 feet of topsoil had been <br />replaced on the sample area. The Division finds that <br />topsoil on the partial Phase II/111 release areas has been <br />replaced in accordance with the approved permit <br />requirements. <br />Phase II Vegetation Standards and Sampling Methods <br />for partial Phase II/III areas <br />Map 1B, SL7 Area Delineation Map submitted with the <br />SL7 application shows the chronological order of parcel <br />seeding as does Exhibit B, Chronological Revegetation, <br />submitted with this application. Most areas were drill <br />seeded with the appropriate seed mix while steep slopes <br />were broadcast seeded at twice the drill rate. Revege- <br />Photo 2: Rosa woodsii are plentifultation success criteria and success demonstration <br />throughout the site. <br />methods are presented in Tab 22 of the approved permit. For Phase II bond release, cover is the only <br />criteria required. Transect data tables, sample adequacy calculations, diversity calculations and <br />species lists are presented in Attachment D of the SL7 application. However for Phase III bond <br />release the applicant must meet all vegetation success standards: herbaceous cover, herbaceous <br />production and species diversity which is discussed later in this document. <br />Vegetation Cover Success <br />The revegetation success standard for cover is dependent on comparisons, based on statistically <br />valid sampling of the reclaimed areas and extended reference areas located in undisturbed areas <br />within the permit boundary. Within the extended reference areas SPL maintains a minimum acreage <br />of each community type. Four major pre mining community types (Aspen, Mountain Brush, <br />Sagebrush and Steep Mountain Brush) disturbed during the life of the mine are represented. <br />Weighted averages for cover and production comparisons are derived from the percentage that each <br />community type was present in the pre -mining surface area affected by mining. Success is <br />demonstrated if statistically adequate sampling and testing pursuant to Rule 4.15.11 demonstrate that <br />the revegetated area cover is not less than 90% of the extended reference area cover at 90% statistical <br />confidence. Refer to pages 32-45 of Tab 22 in the permit application package for a narrative <br />describing the extended reference area approach for measuring revegetation success and for <br />additional details associated measuring success standards. <br />DRMS concluded that vegetation sampling occurred according to methods prescribed in the permit <br />as per permit Tab 22 and, that sample adequacy was achieved by methods described in rule <br />4.15.11(2)(a) for some criteria but not all. Where sample adequacy was not achieved the reverse null <br />was performed as per the above rule, and adequacy requirements met. <br />For 2015 the allowable all hit herbaceous vegetation cover sampled in the BRB2 area was 69.8% and <br />for the year 2016, 71.3%. The 2015 standard to be met was calculated to be 48.7%, and the <br />Permit Number C-1994-082 Page 11 of 23 <br />
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