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(e) Depth of Cover Requirement -Development Waste Pile (DWP) and <br />• Refuse Disposal Area (RDA). <br />Picketwire Processing (PPLLC) is reviewing the suitability of instituting an Alternative <br />Cover Requirement for the DWP and RDA. PPLLC is using an Abandoned Mined Lands <br />(AML) reclamation project adjacent to the New Elk Mine as a basis to develop an <br />alternative practice. AML reclaimed an old mine waste dump in 1990. This dump was <br />active in the 1950's and abandoned by CF&I's Allen Mine prior to 1977. It was never <br />included in the New Elk permit. Composition of the pile is believed to be similaz to the <br />New Elk DWP. <br />AML completed the reclamation of the waste dump using cover averaging twelve inches <br />of alternative soil material. The reclamation success of this project was evaluated in <br />2001 using procedures proscribed in the New Elk permit for evaluating revegetion <br />success. This study can be found as Exhibit 36 of the New Elk permit. <br />After almost ten years since completion of reclamation, the AML azea appeazs to support <br />a healthy stand of perennial grasses and forbs. The site appeazs to be physically stable <br />with no signs of significant erosion. The azea meets the standazds for herbaceous <br />production, cool season grass diversity, perennial forbs diversity, and woody stem <br />density. The survey area did not meet the standards for percentage cover and species <br />diversity for warm season grasses. <br />• The vegetation cover requirement was not met possibly for several reasons including soil <br />nutrient deficiencies and grazing. The proposed reclamation plan will include a soil <br />testing and enhancement program and the azea will be fenced to restrict domestic grazing <br />activities. <br />The likely explanation for the area not meeting the warm season grass species diversity <br />standard is that warm season grasses were under-represented in the seed mixture used as <br />part of the AML project. The seed mixture was comprised of 13 percent warm season <br />grasses and 70 percent cool season grasses. The seed mix developed as part of the Mine <br />Permit is comprised of 39 percent cool season grasses and 40 percent warm season <br />grasses. As a result, areas reclaimed using this seed mixture aze expected to meet the <br />species diversity standard. <br />DWP Reclamation Plan <br />1. Side slopes will be graded to no steeper than 2(H):l(V) slope prior to cover <br />placement. <br />2. An average of no less than two foot of cover material including a minimum of <br />nine inches of suitable topsoil or topsoil substitute material will be placed over <br />the graded slopes. <br />3. Soil samples will be collected on no greater than 100 foot centers. Each <br />location will be sampled in increments 0-9" and 9-24". The upper increments <br />will be analyzed individually for the criteria listed in Table 25A Soil Test <br />Parameters. A representative composite of the 9-24" increment will be <br />• <br />TR-47 Z.OS- 47 Revised 1/24/03 <br />