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-4- <br />j) A rill and gully plan should be included which discusses <br />maintenance and repair of gullies which form on reclaimed <br />areas. This plan should include a monitoring schedule, a <br />repair schedule, and a description of the repair <br />methodology which considers minimization of the disturbance <br />to revegetated areas as a result of gully repairs. A copy <br />of the Divisions' rill and gully plan policy memo is <br />included for your guidance. <br />k) The revised borehole sealing diagram should be inserted <br />into the permit. <br />1) A copy of the spill containment plan should be inserted <br />into the permit. <br />m) The narrative which describes subsidence prevention and <br />control should be expanded to explain and substantiate <br />assumptions in the plan. For example, does evidence exist <br />which demonstrates that houses will not crack with 4-5" of <br />subsidence? <br />5) Exhibit 1 <br />a) The new insurance certificate should be inserted into this <br />section. (See III (3)(d)). <br />6) Exhibit 5 -Cultural and Historic Information <br />a) The study performed by Mr. Campbell indicates one lithic <br />scatter site of importance. WFC should discuss what has <br />been done to protest this site, including mitigation of the <br />impact of pond 002 A and B construction. <br />7) Exhibit 7 - Hydrology and Geology Information <br />a) The monitoring program described on page 59 should be <br />updated to reflect approved revisions. In addition, the <br />operator should update assumptions and review the proposed <br />change in monitoring as described in the New Elk mid-term <br />review (Exhibit 7). <br />8) Exhibit 7 - Overburden and Interburden Analysis <br />a) The overburden chemistry presented in this section <br />indicates high SAR, metals, and sand percentage. WFC <br />should discuss how these elevated levels may affect <br />reclamation, and what mitigation measures if any, will be <br />needed. <br />9) Exhibit 9 - Water Quality Analysis <br />a) Many of the tables included in this section do not include <br />specific site descriptions. For example, Tables 1-6 are <br />all titled "Purgatoire River, April 19, 1979." If these <br />can be identified more specifically, please do so. <br />