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7. 3.2.4.2 Demolition Materials Disposal: Henderson applies the same unit cost to reclaim dte Tailing <br />Building and Road Area (Task 18b) as the Landfill. This may not necessarily be the case because it <br />depends on the location of.the material to cover the landfill (4840 LCY as stated by Henderson). Please <br />describe the nature and location of the borrow material that will be used to cover the landfill. Once this <br />information is provided to the bivision, a cost can be estimated. <br />8. 3.3 Structures to Remain: Rule 3.1.11 of the Hazdrock/Metal Mining Rules and Regulations of the <br />Mined Land Reclamation Board states: <br />Tf the affected land is owned by a legal entity other than any local, state, or federal entity, any <br />buildings or structures including those constructed or placed on the affected lands in conjunction <br />with the mining operations or which are historic structures as determined by the State Historic <br />Preservation Office may remain on the affected land after reclamation at the option of the Operator <br />and Landowner if such buildings or stmcmres will not conflict with the post-mining land use, and <br />with the approval of the Board. <br />It is clear that the East Branch Reservoir pumpstation and the Williams Fork pumpstation meet the criteria <br />of Rule 3.1.11 and the cost of demolition of these facilities will be eliminated from the working <br />reclamation cost estimate. Likewise, the Division concurs that the Ute Pazk pumpstation will serve a <br />valuable post muting use and will eliminate its demolition cost from the estimate. The issue of the culverts <br />and bridges through [he embankment that supponed the former haulage rail line is somewhaz more <br />complicated. Currently Henderson owns the land where these stmctures are located. Land ownership is <br />one of the considerations under Rule 3.1.11. The Division agrees that allowing these structures to remain <br />in the post reclamation landscape may be desirable to the landowner and surrounding Landowners, and that <br />these sttvcntres do not necessarily conflict with the approved post mining land uses. However, these <br />structures may require periodic and ongoing maintenance and it is the Division's understanding that some <br />or all of these stmctures may be on land that will revert to National Forest at the conclusion of mining. If <br />this land will eventually fall under management of the U.S. Forest Service, the Division will require USFS <br />concurrence to leaving the bridges and culverts in place prior to elimination of the demolition costs from <br />the estlmate. <br />9. 3.4 Tree and Shrub Planting; Henderson proposes to eliminate all tree and shrub planting from the mine <br />and mill by changing the end land use from "open forest" to "rangeland." The Division has determined <br />that the total elimination of tree and shrubs from the reclamation plan would require an amendment to the <br />permit as a significant change in the reclamation plan. The definition of rangeland includes wooded areas <br />and fits with the currently approved post mining land use of open forest. The Division will approve a <br />reduction in the tree and shrub planting requirement as a Technical Revision to the permit. The Division <br />recommends the following or a variation thereof as a reduced tree &shmb standard; <br />• No need for tree or shrub transplants on areas of disturbance that are 5 acres and less if each 5-acre <br />parcel is separated from each other by at least 200 feet, i.e., no tree and shrub planting on small <br />isolated disturbances. <br />• The 340/acre trees and shrubs standard on the tailings pond can be eliminated, in exchange for a <br />proposal of small islands of shrubs throughout the tailings area (the shmb islands would require a <br />thicker topsoil layer than the majority of tailing surface seeded to grass). <br />• On azeas greater than 5 acres, a reduction of trees and shrubs to 200 per acre at 15-foot centers with a <br />75% survival rate, or small islands of trees/shrubs at a higher density. <br />I0. 3.5.1 141ine Water Treatment; The Division concurs that pumping and treating mine water from <br />underground can be reduced to 4 months. <br />Henderson provided the Division with information suggesting a water treatment cost of $440 per gpm and <br />supplied supporting documents comprising the budgeted and actual costs for water treatment at the <br />Henderson Mine over the past three years. In each of the past three years, the documents show drat there <br />has been significant variance from the budgeted costs; in 2000 and 2001, these variances were in excess of <br />