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<br />Candy Thompson <br />6. The topsoil salvage section <br />to show the actual location <br />volumes. In addition, NCEC <br />boulders encountered during <br />salvage volume and the reap <br />- 3 - February 3, 1987 <br />on pages 4-62 and 4-67 should be amended <br />of topsoil stockpiles and the stockpile <br />should discuss how the large number of <br />topsoil salvage has affected to total <br />~lication plan. <br />7. The revegetation success criteria on page 4-71 should be revised to <br />reflect the permit stipulation commitments. <br />8. As I have previously stated, references to the refuse disposal area <br />should be deleted until a plan is approved by the Division. One <br />area which will need to be revised with respect to the refuse plan <br />is the revegetation test plots, which are designed to demonstrate <br />that 4 feet of cover is not necessary on the pile. Upon review of <br />the study design (page 4-71 a) it is apparent that the sample plots <br />will not approximate the reclamation plan. The study calls for test <br />plots, with 1 foot of coarse material followed by up to 3 feet (0-3 <br />feet) of topsoil on a flat surface. The reclamation plan calls for <br />0-3 feet of coarse material covered by 1 foot of topsoil on a 2:1 <br />slope. In addition, the fertilizer and mulching rates are different <br />in the study versus the reclamation plan. I believe that the <br />revegetation study plots should be revised to more closely <br />approximate final reclamation conditions, so that more meaningful <br />results can be generated. <br />9. On page 4-751 a post-mining land use of "light industrial" is <br />mentioned as a possibility. This should be deleted unless it has <br />been specifically approved by the Division. <br />10. The monitoring discussion on page 4-90a should be updated to include <br />the specific monitoring requirements as included in permit <br />stipulations. <br />11. Within the facilities relocation TR, Phase A production is increased <br />from 600,000 tpy to 1,325,000 tpy and refuse generation is decreased <br />from 2% to 1%. The result is that no additional refuse is generated <br />although production is doubled. Nf.EC should justify this discussion <br />and explain how refuse generation will be halved. <br />IV. Bond <br />As indicated previously in this memo, some problems exist with the NCEC permit <br />which hinder calculation of the bond. The lack of clarity and the poor volume <br />calculations are examples of such problems. A summary of my bond calculations <br />is contained in the table below. Based on these calculations, NCEC has <br />sufficient bond to cover the existing disturbance, and would have enough <br />coverage to construct all phase A facilities except the rail spur and <br />loadout. As previously mentioned, this loadout could not be constructed until <br />the refuse area or other disposal site for ballast is approved. Additional <br />bond would need to be submitted at that time. <br />