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2. On Table 9-9-1 titled, Final Reclamation Topsoil Management Plan, Seneca determined <br />the average replacement depth for each area by dividing the acre-feet of topsoil in the <br />stockpile by the replacement acres. While converting the topsoil to inches, Seneca <br />rounded off on the replacement depth. In doing so, roughly 10.6 acre-feet of topsoil is <br />not accounted for. Considering the shortage of topsoil at the Seneca II Mine, the Division <br />believes that all topsoil should be adequately accounted for at the mine. Please revise the <br />table accordingly to take into account the 10.6 acre-feet of topsoil. <br />Again, on Table 9-9-1, Seneca has an average replacement depth of 12 inches for the <br />Shop azea using a replacement area of 5 acres with 1 acre-foot of available topsoil. The <br />Division calculates 2.4 inches of replacement depth rather than 12 inches as noted by <br />Seneca. Please revise the table accordingly. <br />4. Exhibit 9-3a was compazed with the new exhibit 9-3c. Three aeeas of topsoil replacement <br />were omitted from the map submitted to the Division; roughly 19.5 acres south of area <br />001 (road to the pond), 1.8 acres on the azea marked corral and 5 acres of the area marked <br />0.0. Please inform the Division why these aeeas are no longer designated on the map for <br />topsoil or subsoil replacement. <br />5. Seneca did not address how much topsoil or subsoil will be placed at the bone-yazd areas. <br />Please revise the permit pages and map accordingly. <br />6. Seneca has informed the Division on numerous occasions that the post mining road <br />location, depicted on Exhibit 12-9, will change. Stipulation #32 of the permit renewal <br />requires that Seneca submit a detailed reclamation plan and landowner consent to leave <br />the road in place. Exhibit 9-3c does not depict the road location that would need topsoil <br />replacement. The Division believes that the final road location and the requirements of <br />stipulation #32 need to be addressed to accommodate the ongoing reclamation and the <br />topsoil management plan in this revision. Please update the maps depicting the <br />anticipated road locations and address the requirements noted in stipulation #32. <br />On Table 9-9-1 and Exhibit 9-3c, Seneca notes that azea 004 will receive 24" of subsoil <br />material. Please inform the Division where Seneca will get the subsoil material to be <br />used in area 004. <br />8. Seneca proposes to reclaim area 006 (the upper Wadge Pit) without topsoil. This azea <br />will include some of the steepest reclaimed slopes on the mine. The erosional stability <br />and the feasibility of successful reclamation of this azea without benefit of topsoil would <br />appear questionable. In addition, the potential for noxious weed infestation on an area of <br />baze spoil of this size would appear to be very difficult to manage. Prior to considering <br />approval of reclamation of areas without topsoil, we believe the following options need to <br />be throughly explored; <br />