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SECTION V -DECISION TO REQUIRE REVISIONS <br />The Division has conducted a mid-term review under Rules 2.08.3, 2.06.2(a), <br />2.06.3(4), 2.06.5(3), 2.06.7(5) and 3.02.2(4). The review inc]uded the <br />Edna Mine permit application, all subsequent revisions, all stipulation <br />responses, hydrologic monitoring data, past inspection reports, and on site <br />inspections. The Division finds that certain revisions and modifications are <br />needed to ensure future compliance with the Colorado Surface Coal Mining <br />Reclamation Act and the Regulations of the Colorado Mined Land Reclamation <br />Board for Coal Mining. The following section details the modifications <br />required and justification for those revisions. Please submit a mid-term <br />review revision by May 31, 1990, in a packet which includes responses to <br />questions asked and revised pages for inclusion in the permit application. <br />1. The permit application form situated at the front of Volume 1 of the <br />permit application must be updated to show current names, addresses, <br />contacts, etc. <br />2. A revised table of contents must be submitted for the permit <br />application. The table of contents must include all additional or <br />revised exhibits and maps, and a list of all supplemental material that <br />has been submitted, including stipulation responses. This information is <br />necessary to insure that the permit application is accurate and canplete. <br />3. The soil survey maps (EXHIBIT 2.3-1, SHEETS 1 AND 2) must be properly <br />certified to comply with Rule 2.10.3(2). <br />4. The seed mixtures and specific reclamation techniques that will be used <br />for final reclamation of the two approved stream buffer zone exemptions <br />should be detailed. <br />5. The topsoil storage pile for the Trout Creek Diversion must be located on <br />Exhibit 4.3-1. The topsoil removal and storage plan in Section 4.3 must <br />be modified to address the disturbance related to the Trout Creek <br />Diversion. Include these acreages of disturbance and topsoil volumes in <br />the Moffat area tables and narrative to comply with Rules 2.05.3(5) and <br />4.06.2. <br />6. Please state how stream buffer zones will be marked in accordance in <br />Rules 4.02.5 and 4.05.18. <br />7. Please change the statements in lab 2.4 - Vegetation to reflect that some <br />of the Willow/Red top vegetation unit will indeed be affected by mine <br />related activities (Trout Creek Diversion). <br />8. Rule 2.05.4(e)(vii) requires that coal mine operators submit a plan for <br />testing reapplied topsoil Rule 4.06.5 elaborates on what sort of <br />information should be included in the plan. Section 4.3.5 of the permit <br />application addresses both the topsoil sample collection strategy and <br />P&M's intention to have lab analyses done on each sample. However, the <br />narrative does not address which parameters will be tested for in the lab <br />analy sis. The narrative also lacks specific information addressing: <br />1) the success criteria for determining if soil amendments will be <br />necessary, and 2) what form these amendments will take. Please revise <br />Section 4.3.5 to incorporate this informatibn. <br />-9- <br />