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~~ Page 2 Rockcastle Company ile /k78-45 ~ • 4) Your soils information indicates a very acid soil at "Stop ~p2" in the report. This may be either a typographical error or possibly an indi- cation of poor soils. Please look into the matter and, if necessary, you may have to perform additional soils tests at Stop ~i2 to determine the extent of the problem. If acid soils do exist in the area, you will most likely be required to bury them and definitely not to use them in reclamation. 5) Please submit as much information as possible regarding the groundwater in the area. It may be that you will not be required to do groundwater monitoring (as required in the OSM Regulations) if you can make a show- ing that you will be operating well above any perched or continuous aquifers. 6) Reclamation Plan - As with your mining plan, you need to more clearly explain the sequence of reclamation operations, referencing the maps and timetable as much as necessary. I would also encourage you to include more shrub transplants in your plan, as recommended by the Wildlife Conservation Officer from the area. Your seeding mixture could be improved upon by including more native species and fewer introduced species. The Energy Fuels Mine has initiated an innovative practice of hiring schoolchildren to collect seed from the native plants and shrubs in the area so as to insure a greater success rate withthe already-adapted species. You can refer to their seeding mix- ture, a copy of which I gave you during our meeting, and possibly use it as a model for your own mixture. Energy assures me that they are .spending less money and creating better public relations with their new method of obtaining seed, so I am sure Rockcastle would be inter- ested. Furthermore, the new OSM Regulations require that whenever non-native species are used, supporting information must be submitted to demonstrate the adaptability and utility of those species. In addition, the Federal Regs require that you use mulch in your revege- tation process. You will be required to submit plans for such. 7) you will be required to respond to the comments made by the Division of Water Resources in their memo of March 14, 1978, and the Division of Wildlife in their memo of April 5, 1978. 8) You should explain the relationship of Consolidated Energy to the Grassy Creek Coal Company since the surface lease is in their name. The lease does not specifically state that Bogle Farms, Inc. owns the surface rights, so you should either get a notorized statement from them saying as much, or submit a copy of their deed or title to the land. 9) You will be required to address each section in Part 715 of the Federal Office of Surface Mining Regulations and explain how your operation will comply with each performance standard. You may reference the letter of clarification you will be sending me, as well as the original permit application, but you must very specifically outline the plans Grassy Creek will follow to effect compliance with the OSM Regulations. In summary, I will expect two submittals from you; a letter of clarifica- tion addressing the points raised in this letter, and four copies of the supplement addressing the Federal Regulations. To be on the safe side, I would recommend that you submit four copies of your letter of clarification as well.