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presumed amendment map from July 1983, and a map from September 1983. (These are on <br />the microfiche which I am not sure of you saw.) These maps include dated vent hole <br />openings, and shaded areas represented as (affected) areas to be reclaimed. As far as legal <br />descriptions for all affected areas, it would not be that important if the Division had assurance <br />that the affected areas were accurately depicted on the maps, all disturbance was inventoried <br />and reported, and that the maps were absolutely current, correct and complete. <br />L. I was incorrect in calling the 20 acres at the portal azea the "permit acreage." However, the <br />fact that the 1998 map contained a boundary which differed in configuration and acreage than <br />that shown on previous maps calls into question the reliability and correctness of the new <br />map. The permit allows 20 acres (of the total 40 acres) of affected area at this location. <br />M. My statement should have been worded "affected azea," not "permit acreage." The mining- <br />related disturbance which occurred after permit issuance is to be bonded and reclaimed. It <br />will likely include tasks such as closure of the opening, grading, possible topsoil spreading, <br />ripping, clean-up of debris, structural removal and revegetation. To address your last <br />question under this point: NSA's use of the GMG # 13 site requires that it be included in the <br />40 acres of affected area. Since the permit allows flexibility in location and development of <br />facilities (up to a maximum of 40 acres) within the larger 755 acres of permit area, the fact <br />that this was used but never bonded or reported on a map, is only a problem (not a possible <br />violation). An unusual but fortunate detail in this permit. <br />N. As explained above, the requirement has always existed, but there may have been factors why <br />the problems were not recognized or addressed. At this time, the problems are recognized, <br />correcting them is required, and an attempt must be made to do so. Much of this comes down <br />to two issues: proof of right-of--entry and adequate bond amount. We must know that all <br />affected areas aze on land for which IUSA has no problem with right-of--entry, since many of <br />the areas presently are near the edge of the claim block comprising the permit boundary. So, <br />locating all areas on a map is essential. The types and amount of disturbance to be reclaimed <br />is the reclamation liability, and the State does not wish to be in a position of footing the bill <br />for unbonded reclamation liability. So, that is another reason we must resolve these things. <br />O. Again, the point you raise is in reference to a comment in my letter which pertained to 110 <br />and 112 permits. My answer is the same as that given in (1J) above. <br />P. OK. <br />Q. One example: In relation to the maps (let's use the 1983 map you saw), the current dump has <br />very possibly been considerably expanded toward the west. This raises the issues of a map <br />we are not sure we can rely on, and that there were no boundary markers available to verify <br />the extent of the affected area (or the permitted area boundary, which lies in very close <br />proximity, in this case). Another example: The 20-acre portal azea also exhibited numerous <br />additional structures and possibly more openings than what were depicted on the 1983 or <br />1998 maps. More examples: The GMG #13 decline, discussed above, is a good example of <br />the poor match between actual conditions and those documented in the file. The radio tower <br />on the ridge is shown on the 1983 maps, though it is now completely removed. (Please do <br />not despair about the task of rectifying the shortcomings of the file; IUSA will be given <br />adequate time as long as diligent progress is made and communication remains open.) <br />R. It would be best to mark them all, though I understand that there may be difficulty in some <br />cases. Mazking on-the-ground should at least include one main identified point, which would <br />be referenced on the map, while the map or accompanying text could include an accurate <br />location description of the affected area at that site. As for the map question, it is necessary <br />to show all vent shaft sites on the map, but each of them (as well as all other remote site <br />features, such as overhead and surface power cables, power shafts, fences, cutwalls, roads, for <br />example) must also be better described as to what they consist of This means characterizing <br />the type and extent of the area or structure, sufficient to enable the Division to monitor it and <br />estimate a bond amount for its reclamation. I am becoming fairly certain that many of these <br />