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Dan Mathews March 74 9008 White Top and addressed control plan for Cheatgrass. 16) There is an inconsistency between the current (January 6, 2005 RN-5) Findings of Compliance Document and permit narrative on page 3-17 of the permit application text, with respect to the herbaceous production success standard. The permit text indicated that herbaceous production success would be based on comparison fo the appropriate reference areas. This appears to be erroneous. Division findings documents as far back as the Findings dated April 1986 indicate that combined pre-mine production data (or McClane and Munger permit areas would be used as the success standard /or the McClave Canyon permit for the affected vegetation types (greasewood Shrubland, Shadscale Shrubland, and juniper woodland). Please refer to page 22 Section VIII.D of the January 6, 2005, RN-5 Findings document for clarification. Please amend the text In Section 3.4.9 of the application to clarify that herbaceous production success demonstration will be based on comparison of reclaimed area production to pre-m-ne baseline data for the three affected vegetation types. Please insert the applicable sample mean and standard (90% of the mean) for each of the three affected vegetation types. CAM -Changed text to demonstrate herbaceous production will be based on comparison of reclaimed area production to pre-mine baseline data for the three affected vegetation types. Inserted applicable sample mean and standard for each of the three affected areas based on Division findings dated January 6, 2005 (RN-5). Removed last three sentences of 3-17 and replaced with DMG suggested text. 17) Some minor additional changes to the text on page 3.4.9 are requested to reflect the various revegetation rule changes recently approved by the Mined Land Reclamation Board. Beginning with the third to last sentence of the first paragraph on page 3-17, we suggest the tent be replaced with the /ollowing revised wording: Statistical adequacy demonstration and tests of revegetation success will be made using formulas specified in Rule 4.15.11. Sampling techniques used forcover, production and woody plant density w111 be comparable to baseline sampling techniques and will be !n conformance with Rule 4.15.11. Cover will be sampled using a point intercept technique, production by clipping quadrats and oven drying the clippings, and woody plant density by a quadrat method. Amore detailed plan for bond release vegetation sampling will be submitted and approved prior to initiation ofsampling forPhase ll orPhase Il bond release. CAM -Made suggested changes to page 3-17 18) Section 3.7.2 of the permit application includes an acceptable plan for drill hole permanent sealing. We incude a reminder that Rule 4.07.3(3) requires that proof ofcompliance be submitted to the Division within 60 days after abandonment o/ a drill hole. Please provide an abandonment report /or the emergency drill hole sealed In early January 2006, within 60 days. CAM -Submitted under separate cover 19) The discussion o/Probable Hydrologic Consequences on pages 2-44 through 2-46 was last revised in 2001. Please update the narrative as warranted to encompass hydrologic conditions encountered from 2001 to present time. CAM - Changed the maximum mine discharge on page 3 of Appendix N to 100 gpm, reduced TDS value in table from 3260 to 3230 based on 2001-2005 DMR's. On page 2 of Appendix N, changed length of saturated zone from 4300' to 4500' based on page 1, second paragraph. Updated PHC discussion on pages 2-44 through 2-46. 20) Page 4-34 was last revised in January 2000, and does not include references to the most recently updated wafer depletion estimates and USFWS Biological Opinion (B.O.) documentation. Please amend the narrative of page 4-34 to include reference to the January 2002 Water Consumption Estimate of 13.39 acre-feet per year(Appendix P), and the associated January 2002 USFWS B.O., which notes an additional annual depletion projection of 7.49 acre-feet (and notes that the depletion lee is waived). We recommend that the 2002 USFWS B.O. document be incorporated into Appendix P. CAM -Revised page 4-34 to include information from 2002 Biological Opinion (BO). Paginated 2002