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test plots, which are designed to demonstrate that 4 feet of cover is <br />not necessary on the pile. Upon review of the study design (page <br />4-71a) it is apparent that the sample plots will not approximate the <br />reclamation plan. The study calls for test plots, with 1 foot of <br />coarse material followed by up to 3 feet (0-3 feet) of topsoil on a <br />flat surface. The reclamation plan calls for 0-3 feet of topsoil on a <br />flat surface. The reclamation plan calls for 0-3 feet of coarse <br />material covered by 1 foot of topsoil on a 2:1 slope. In addition, the <br />fertilizer and mulching rates are different in the study versus the <br />reclamation plan. The revegetation study plots should be revised to <br />more closely approximate final reclamation conditions, so that more <br />meaningful results can be generated. <br />9. On page 4-751 a post-mining land use of "light industrial" is mentioned <br />as a possibility. This should be deleted unless it has been <br />specifically approved by the Division. <br />10. The monitoring discussion on page 4-90a should be updated to include <br />the specific monitoring requirements as included in permit stipulations. <br />11. Within the facilities relocation TR, Phase A production is increased <br />from 600,000 tpy to 1,325,000 tpy and refuse generation is decreased <br />from 2% to 1%. The result is that no additional refuse is generated <br />although production is doubled. NCEC should justify this discussion <br />and explain how refuse generation will be halved. <br />V. Bond <br />As indicated previously in this memo, some problems exist with the NCEC permit <br />which hinder calculation of the bond. The lack of clarity and the poor volume <br />calculations are examples of such problems. A summary of bond calculations is <br />contained in the table below. Based on these calculations, NCEC has <br />sufficient bond to cover the existing disturbance, and would have enough <br />coverage to construct all Phase A facilities except the rail spur and <br />loadout. As previously mentioned, this loadout could not be constructed until <br />the refuse area or other disposal site for ballast is approved. Additional <br />bond would need to be submitted at that time. <br />