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s <br />Mr. William T. Davis - 8 - April 25, 1989 <br />A soils analysis must be provided for determining the viability of the soil as <br />a growth medium after redistribution. The application contains a statement <br />that "nutrient reconditioning shall be applied to the redistributed topsoil if <br />recommended by the Division or the local SCS". It is recommended that the <br />operator commit to a soil test (as required by Rule 4.06.5) after <br />redistribution to determine soil suitability, nutrient content, and <br />specifically fertility requirements. The analysis should include but not be <br />limited to: pH, percent OM, EC, SAR, N, P, K, Texture, and Saturation <br />percent. This commitment should be incorporated into the text of the <br />application. <br />Rule 2.05.4(2)(e) <br />The Division requires all available topsoil be replaced, not a minimum of 4 <br />inches. If grading to a minimum of 4:1 slopes is followed, how will this be <br />accanodated within the Division's AOC requirements? The seed mix described <br />will produce 37.9 seeds per square foot which is acceptable, but by only <br />planting two species, it is doubtful that the site will meet whatever <br />reclamation standards are established for species diversity. Other species <br />which should be considered might include needlegrass, big and little bluestem, <br />blue grams, muttongrass and Indian ricegrass. A legume such as titer <br />milkvetch is also desirable as well as some additional shrub species besides a <br />"trace amount of Mountain tAahogany". <br />A seed mix should also be proposed for stabilization of the topsoil stockpile. <br />The applicant states that standards for revegetation success will be set by <br />Rule 4.15.7 (2 )(d)(vi). This section is applicable for permit areas totaling <br />40 acres or less. The application form shows an area of 47.85 acres. The <br />applicant may elect to either propose a different revegetation success <br />standard or reduce the size of the permit area. <br />Prior to the establishment of success standards, the Division must receive a <br />baseline vegetation report for the permit area in order to determine the <br />current vegetative cover, productivity, diversity, and woody stem density at <br />the site. <br />Rule 2.05.4 (2)(f) <br />Are acid forming or toxic materials anticipated? If not, is there evidence to <br />support such conclusion? If so, then based on the anticipated nature, what <br />specifically is the disposal plan so as not to pose a threat to water quality <br />an r~ evegetation success. <br />Are used lubricants to be disposed of offsite? If so, a commitment to this <br />should be made. If these lubricants or other liquids or their containers are <br />to be disposed of onsite, all the requirements of Rule 4.11.4 apply and <br />appropriate water barriers must be provided for the disposal facility. <br />Rule 2.05.4 (2)(g) <br />The plugging proposal which should apply to well 29-4, the monitoring well, <br />does not conform to the requirements of Rule 4.07.3(2) for wells completed in <br />aquifers. <br />