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- 13 - The proposed topography results in a 3200' long, 75' deep trench with 3: sideslopes in the Pit 3 area and the construction of two pyramidal spoil piles over 100' high with 18° slopes, This topography does not resemble the pre-mining topography of the site and does not result in the elimination of spoil piles. Post-mining slopes generally exceed pre-mining slopes, which is not acceptable under 4.14.2(1). This topography is depicted in the accompanying post-mine topography perspective drawing. The reclamation plan should result in a topography which blends into and compliments the drainage pattern of the surrounding terrain. The KCC plan cuts off two ephemeral drainages onto a moderately sloping (3:1) terrain and funnels the water south, through the Dit area prior to discharging into Williams Draw. This design does not compliment the original drainage of the area, nor does it attempt to mitigate any of the resulting erosional characteristics of the backfilled spoils. Please revise the reclamation plan to met AOC per Rules 1.04(13) and 4,14.1(2). In particular, review backfillina and grading plans for Pit 3. 53. Please modify the rill and gulley mitigation plan to describe the timing of stabilization actions, Include, at a minimum, a commitment to submit the results of a rill and gully survey to the Division by a specific date each year, and assign a date at which time all mitigation work for the field season will be performed. Protection of Fish, Wildlife and Related Environmental Yalues - Rules 2.04.11, 54. The 1981 Findings refers to replacement of .antelope fence at the termination of mining activities. What was the source of this discussion and where is it described in the permit application? Does this relate to conditions BLM imposed upon relocation of Jackson County Road 12 East? Alluvial Valley Floor Determination - Rules 2.06.8 and 4.24 55. In 1986 the Division found proposed to be disturbed by contain an alluvial valley under the applicable rules, reflect that finding. Excess Spoil that the section of Sudduth Draw that was mining under approved Permit C-80-006 did floor which was required to be treated as such Please revise the permit application to 56. Excess spoil piles are specifically discussed by Rules 4.14.1(2)(d) and 4.09. Kerr must make a demonstration through mass balance calculations and analyses of swell that there is excess material for disposal beyond that required to re-establish a semblance of the pre-mine topography. Thus, Exhibit 25 and Table 63 must be revised following modification of the reclamation plan to document a specific volume of excess material from each pit. At this time, the Division does not agree that there are