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Memo - Cathy Begej - 2 - January 24, 1990 1981 Soil Testing Plan According to Exhibit 1 of the permit application WFC committed as follows: "Wyoming Fuel (will) test the soil for fertilization every year for the next three years. As soon as the results of the soil tests are available they are to be forwarded to the Division. At the end of three years WFC must request that the Division terminate the soil test requirement and include the necessary soil test data that justifies the termination." This commitment stemmed from a 1981 minor revision and thus would have required sampling through 1984 at least. Required submittals cannot be located in the permit correspondence. Please submit all pertinent information regarding this minor revision. The Division would prefer that this soil sample data and other communications resulting from this plan be prepared as an inclusion to Exhibit 1 and that the permit application (page 65) reference this data. Additionally, please indicate to the Division the relationship between the soil plan outlined in Addendum 2 and the soil plan noted in Exhibit 1. 1987 Soil Testing Plan The permit application does not presently address a soil testing plan for the area reclaimed in 1987. Response 4 of the September 19, 1986 letter from David Stout to Steve Renner (RE: Response to Adequacy Issues, TR-03, Reclamation of Canadian Strip Mine) committed to a program for testing topsoil for nitrogen, potassium, phosphorous, and pH. Please revise the application appropriately to indicate what testing was done, what sampling methodology was followed, what results were obtained and whether fertilization was necessary and carried out. Rill and Gully Inclusion The Rill and Gully Plan that is outlined in the 1986 permit renewal adequacy response letter from David Stout to Steve Renner (dated: 10/27/86) should be incorporated into the present permit application. In addition, please note the map submittal commitments that are part of the plan description. Appropriate submittals were not located in our files. Please submit copies of previous correspondence relating to WFC's annual rill and gully inspections. II. Revegetation 5. Plant Communities to be Disturbed Page 2.04-1 of the Permit Renewal Application states, "WFC did not disturb any alkali sagebrush community, therefore, none will be reclaimed." The permit application should be revised to reflect this information. For your information: Figure 1F, the Vegetation Map, shows vegetation communities as they exist in undisturbed parts of the permit area. The map does not show communities inside the disturbed area. The statement that no alkali sagebrush community was disturbed appears to me to be false. However, this is to the Division's advantage because the alkali sagebrush community has lower production and cover than the big sagebrush community.