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2019 at Pond 016 and between 2005 and 2010 at Pond 017 show TSS to be significantly less than the pre <br /> mine average and maximum concentrations. So,although an increasing TSS trend is shown at stream point <br /> WSH7 the reclaimed parcels are stable and the trend appears unrelated to runoff from the reclaimed site. <br /> Cover Analysis <br /> Vegetation sampling was conducted in 2015 and 2016. The SL6 application was received in the fall <br /> of 2019, making the vegetation data submitted within the 4 year acceptable time period. Post-mining <br /> land use is livestock grazing and wildlife habitat. <br /> The sampling requirements assume a normally distributed sample, and requires achievement of sample <br /> adequacy. The reference area did not exhibit a homogenous distribution of vegetation, and was diverse <br /> in structure and herbaceous cover distribution. This is actually preferred over a homogenous <br /> community,however, it presents challenges when applying statistical formulas presented in Rule <br /> 4.15.10(2). <br /> Seneca Properties presents the results of allowable herbaceous cover data sampling for 2015 and 2016 in <br /> SL6 Table 2. Bond Release Block 3 (BRB3)met sample adequacy in 2015 with 54.6% allowable <br /> herbaceous cover. Of the 5 reference area communities making up the acreage weighted reference area <br /> standard,4 met sample adequacy,but one,the steep mountain brush community did not. SPL provided <br /> calculations on the steep mountain shrub data set to documents its acceptability. Ninety percent of the <br /> 2015 allowable all-hit herbaceous cover for the acreage weighted reference area calculated to be 43.2%. <br /> The bond release parcel BR133, exceeded the 90%reference area standard, and is successful for the 2015 <br /> cover requirement. <br /> Bond Release Block 3 (BRB3)met sample adequacy in 2016 with 48.4% allowable herbaceous cover. <br /> Of the 5 reference area communities making up the acreage weighted reference area standard,4 met <br /> sample adequacy,but one,the Western wheatgrass/Alkali Sagebrush community did not. SPL provided <br /> discussion on the Western wheatgrass/Alkali Sagebrush data set to documents its acceptability. Ninety <br /> percent of the 2016 allowable all-hit herbaceous cover for the acreage weighted reference area calculated <br /> to be 40.8%. <br /> The bond release parcel BRB3, exceeded the 90% reference area standard, and is successful for the 2016 <br /> cover requirement. <br /> Summary and Conclusions <br /> Based upon a review of the mine permit,the applicant's bond release application,and site inspections,the <br /> Division finds that Seneca Property LLC has replaced topsoil in accordance with the approved reclamation <br /> plan. Seneca Property LLC has established vegetation which supports the approved post mine land use and <br /> meets the approved success standard for vegetative cover. The Division finds that the reclaimed area subject <br /> to this bond release is not contributing suspended solids to streamflow or runoff outside the permit area in <br /> excess of premining levels or in excess of adjacent nonmined areas. <br /> PHASE III <br /> 378.5 acres of lands requested in the Phase III Bond release application (SL6), are simultaneously being <br /> approved for Phase II release in this permitting action, while 437.1 acres have previously achieved <br /> Phase II bond release. Final vegetation reclamation success was evaluated for vegetative cover, <br /> Permit Number C1982057 Prepared by: R.Reilley MS,GISP <br /> SL6 Phase II and III Page 11 of 16 <br />