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10 <br />23. Comparisons of revegetation success necessary for bond release demonstration are <br />addressed on page 2.05.4-6R, but are somewhat intermingled with discussion of <br />monitoring to be conducted during the liability period. The plan for monitoring of <br />revegetated areas during the liability period, and the plan for statistical <br />demonstration of revegetation success for bond release should be separated. Also, <br />the rules require that production, cover, and woody plant density be demonstrated <br />to be not less than 90% of the approved standard with 90% statistical confidence, <br />rather than 80% statistical confidence as stated on page 2.05.4-6R. As written, the <br />test would be more stringent than required. Finally, the application does not <br />specifically describe the statistical tests to be used in demonstrations pf revegetation <br />success, as required by Rule 4.15.7(2)(d). Sample adequacy formulas and hypothesis <br />test approaches should be specifically described, or if prei'erred, the following <br />statement could be incorporated in the application: <br />For demonstration of revegetation success, vegetation cover, herbaceous <br />production, and woody plant density will be sampled to statistical adequacy, <br />and compazed to the approved standard. Statistical adequacy will be <br />demonstrated using formulas recommended in the Division's current bond <br />release guideline. Statistical tests of success will also follow 'the procedures <br />recommended in the bond release guideline. <br />24. With respect to demonstrations of revegetation success for the Utah Tract, the <br />application indicates that success criteria will be the same as applicable to the waste <br />disposal site, "except that Empire will utilize the applicable Trapper reference areas " <br />Will range sites A, B, and C be individually evaluated in direct comparisons with the <br />specified reference areas, or will a weighted average comparison be employed? The <br />seedmix for Range Site C apparently contained no woody plants. Were shrub <br />seedling transplants or mature transplants utilized within Range Site C reclamation <br />areas? Does the 1000 stem per acre woody plant density stzmdazd apply to Range <br />Site C reclaimed areas? The discussion regarding the Utah Tract needs to be <br />amended to address these issues. <br />25. The application text on Pages 2.05.4-SR and 2.05.4-14R references sampling of <br />surface materials in the area of the SA Portals where no topsoil was salvaged due to <br />pre-law disturbance, and indicates that "the top 6" of overburden will be used to <br />compensate for the deficiency of salvaged topsoil:' The consultant's report in Exhibit <br />27 includes analyses from four sites within the SA Portal area which were sampled <br />by 6" increment to a total depth of 3 feet. The report recommends that the top 6" <br />layer of overburden in the sampled area be salvaged anti stockpiled for future <br />reclamation use. Was the surficial overburden removed and stockpiled as <br />recommended? If not, what measures were taken to protect the materials from <br />erosion, compaction, and contamination pursuant to 4.06.2(4)(b} and 4.06.3? The <br />application and findings document reference certain additional areas where topsoil <br />was not salvaged and where overburden would be substitutt;d for topsoil as a plant <br />