REV96898 - Laserfiche WebLink

Home Browse Search

Mc Roy A. Kazo January 10, 2006 Page 4 For clarity, please amend the statement to indicate that BRB-4 and 5 will be sampled "in accordance with the procedures described for BRB-3..." 6. On page 5 of the appendix, the General introductory discussion under ASSESSMENT OF RECLAMATION ADEQUACY describes the extent to which quantitative data and statistical testing will be employed for BRB-l, BRB- 2, and BRB-3. For consistency and clarity, please insert additional language indicating that, in future bond release applications, BRB-4 and BRB-5 assessments will be in accordance with the procedures described for BRB-3. 7. In the first italicized paragraph under Cover and Production, on page 6 of the appendix, the traditional null hypothesis for cover success testing is described. The second sentence notes that "the factor of 2x... is contained in the Seneca Il permit document." This reference presupposes that the current section of permit Tab 13,. "Testine for Successful Reclamation", which extends from page 13-34 to the beginning of the "Reclamation Schedule" section on page 13-41, will be retained in its current form. However, this could lead to considerable confusion in the future, since many of the success standazds and testing approaches described in the Tab 13 text will be revised or replaced by standards and approaches of the new Appendix 13- 13. In essence, the approved permit would contain conflicting versions of applicable success standards and testing approaches. Deletion of the currently approved "Testing for Successful Reclamation" section might be undesirable, however, due to the loss of documentation of the historical basis for some of the success standard approaches that have been carried forward into the new Appendix 13-13. One possible solution would be as follows. Create a new Appendix 13-14 "Historical Approaches to Testing for Successful Reclamation, Permit C-80-005". Move the entire current "Testing..." section into the new Appendix 13-14. Under the "Testing..." section heading on page 13-34, insert a new paragraph directing the reader to Appendix 13-13 for the currently applicable success standazds and testing approaches, and explain that Appendix 13-14 contains standards and approaches that aze no longer in effect, but have been included in the appendix for historical purposes, and due to the explanation of the rationale for certain approaches that have been retained in the approved procedures of Appendix 13- 13. Please give consideration to the problem presented by retaining conflicting versions of success standards and testing approaches in the approved permit, and propose appropriate amendments to remedy the problem. If the approach suggested by the Division is followed, the sentence referencing the