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Section V -Decision to Require Revisions <br />As a result of this midterm review, the Division will require revision(s) of the permit to address <br />the following concerns with the currently approved Edna Mine permit application. <br />1. Please update the Table of Contents section for the entire permit application, and for each <br />volume of the application. <br />2. Please revise Section 1.0 of the approved permit application package so that it accurately <br />describes the status of operations at the Edna Mine. <br />3. Page 2.2-8, the section on Reclamation of Exploration Drillholes, should be updated to <br />reflect the status of those tasks. <br />4. Appendix 2.4-B contains language regarding revegetation success standards which is <br />confusing and possibly not in congruence with the requirements of Rule 4.15.8. <br />It is not clear that the statistical methodology on pages 8 and 9 would demonstrate that <br />cover and productivity on reclaimed land is at least 90% of that in the reference areas with <br />90% confidence. How was the z statistic on page 9 derived? P&M might wish to consider <br />revising these pages to reflect the use of t-tests for statistical comparisons, as discussed in <br />the Division's 1988 "Guidelines for Compliance with Land Use and Vegetation <br />Requirements' document. <br />Page 9 also states, "In some cases, improved species composition can be substituted for <br />part of the productivity requirement." This statement should be deleted because it conflicts <br />with the productivity requirements of Rule 4.15.8(4). <br />P&M might wish to consider deleting the MLRD "Proposed Policy for Evaluating Species <br />Diversity" from the permit application. This proposed policy was revised prior to being <br />incorporated into the 1988 Guidelines referenced above. <br />5. Page 2.5-1 references expected pit inflows. Please update this paragraph to include <br />observations of pit inflows to date. <br />6. The last three sentences of the third paragraph of page 2.5-1 state "In the absence of <br />fracture permeability, inflows from the alluvium along Trout Creek to the pit in the West <br />Ridge area should be less than 28 gpm. The corresponding value for the Moffat area is <br />anticipated to be less than 16 gpm. in both cases, the most reasonable estimate of flow <br />from the alluvium to the pit are zero." Please clarify this statement, as the last sentence <br />seems to contradict the first two. <br />7. On pages 2.5-1 and 2.5-2, there is a prediction that increases in TDS in Trout Creek due <br />to runoff from the mine will be about 12 mg/1. Please revise the page to indicate what this <br />prediction is based on. <br />Edna Minc (G84001) May 18, 1999 <br />Midterm Rcvicw 9 'niird Pcnni~ Tcrtn <br />