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Item 20. Table of Contents page vii (2/98) appeazs to supersede page xi (MJG/1000/920810) and <br />pages viii (07-03-95) and ix (12/12/96) appeaz to supersede pages xii and xiii <br />(MJG/1 000/9208 1 0). However, pages x (ABC/1145/900806) and xiv (ABC/1145/900301) <br />appeaz to be current. Please repaginate this section or add blank pages to eliminate superseded <br />pages. <br />Item 21. There aze eight permitted variances (Exhibit 4.6-1 and Figure 4.2-3) to Rule <br />4.05.2(3)(a). Demonstrations in support of the variances were found for three (Exhibit 4.7-3 and <br />Figure 4.7-1). Please provide demonstrations in support of other permitted variances where the <br />area(s) were actually disturbed. <br />Item 22. There is conflicting information in the PAP and other sources concerning the acreages <br />of disturbance. Of 81 acres proposed for disturbance (1985), the polygon outlining the limits of <br />disturbance (Figure 4.7-4) encloses 62.56 acres (planimeter). Pages 4-20 and 4-54 of the PAP <br />cite 20 acres, 47.6 acres are reported as affected on page 4-20, and 47.6 acres are reported as <br />disturbed on pages 4-70 and 4-75. Thirty-five acres were reported disturbed in [he Permit <br />Renewal findings of 1997 (page 4). Page 4.6-2a of the PAP cites 12.9 acres of hayland (cropland) <br />disturbed but the Division reclamation cost estimate (1997, Task 26a) used 23 acres. The <br />Division reclamation cost estimate (1997, Task 26b) used 44 acres of pasture/wildlife habitat. (23 <br />+ 44 = 67 acres) The annual reclamation report of 1999 (ARR) reports a total of 46.5 acres <br />disturbed of which 41.5 acres have been seeded. Planimeter measurements (Figure 4.7-2) of this <br />review measured 22.48 acres of cropland and 24.67 acres of rangeland (a total of 47.15 acres, <br />that does not include the azeas of roads, but is still within the magnitude of the ARR). The cost <br />estimate of remaining reclamation work of this review identifies disturbed lands as 20.5 acres of <br />cropland that have been seeded, 2.0 acres of cropland yet to be reclaimed and seeded ([he azea of <br />the sedimentation pond), 24 acres of pasture/wildlife habitat that have been seeded, 1 acre of <br />pasture/wildlife habitat yet to be reclaimed and seeded (the footprints of topsoil piles 2 and 3), <br />and 5 acres of portal slope woody seed mix (already placed). Please reconcile where appropriate <br />the description (acreages) of disturbed lands in the PAP into three parts, cropland, <br />pasture/wildlife habitat, and roads (permanent). <br />Section VI-Bonding Summary <br />The following table presents a summary of the status of reclamation tasks, credits for work <br />accomplished, staged cost estimates, remaining liability of reclamation work, and bond coverage. <br />A copy of the Division of Minerals and Geology Mid-term Review estimate of liability for <br />remaining reclamation work is attached. <br />Task Description Original SL-O1 Renewal3 1999 <br />No.t Estimate` Estimate3 Estimate° Midterm <br /> Review <br /> Estimate° <br /> <br /> Closure of adits, portals, and $8,000 $0 $0 $0 <br /> vent shafts <br /> Removal of project facilities $95,500 $0 $0 $0 <br />