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2.05.3(2) Operation Description <br />5. Various sections of narrative in Section III of the permit application need to be updated to <br />reflect current operational status. Examples include reference to East Portal ventilation <br />exhaust p. III-land III-2, D seam mining narrative (and absence of B seam narrative) on p. <br />III-7 and III-8, outdated reference to East Exhaust Portal facility on p. III-32, <br />6. Various sections of narrative in Section IV and V of the permit application need to be <br />updated to reflect current operational status. Examples include reference to D seam <br />extraction and East Portal ventilation on p. IV-l, and RDH-1 reference on page IV-4. <br />Federal rule citation in second paragraph of p. IV-36 should be amended to appropriate state <br />rule citation. Narrative on p. IV-54 should include reference to Coherex tank at Rock Dust <br />shaft site. Table V-2 on page V-6 should be amended to delete reference to East Portal <br />Area impoundment structures that have been reclaimed. <br />2.05.3(41 Ponds, impoundments and diversions <br />6. The second paragraph on p. IV-39 states that Pond DP-1 decant hole will be controlled by a <br />valve that will normally be kept open, and references Map 80A. The map reference is <br />erroneous, because Map 80A is the Pond SA "As-Built". The correct reference would <br />appeaz to be Map 80B, "Typical Principal Spillway Plans, Sections & Details". Please <br />amend the text as appropriate. <br />7. The DP-1 map version we have (Map 34), appeazs to have been most recently updated <br />September, 1987, and has an "As-Built" designation under "Revisions". The map does not <br />appeaz to show primary spillway detail with the valved decant hole, and does not bear an <br />original P.E. signature. Please amend Map 34 to include the required primary spillway <br />detail or reference the design detail of Map 80B, and provide a properly certified Map 34, <br />DP-1 "As Built". <br />2.05.30 Topsoil Removal; 2.05.4(21~d) Topsoil Removal and Redistribution <br />8. The "reverse sequence" soil handling procedure for cheatgrass dominated locations in the <br />Refuse Disposal Area was approved by the Division based to a large extent on observed <br />reclamation results at RP-1 and at the various refuse area subsoil and topsoil stockpiles. <br />Severe cheatgrass infestation developed on the topsoiled RP-1 fmal reclamation, <br />necessitating complete re-initiation of revegetation efforts 5 yeazs after initial seeding. <br />Observation of revegetation establishment on refuse area subsoil and topsoil stockpiles <br />revealed that, in general, topsoil stockpiles had significant cheatgrass infestation, while <br />subsoil stockpiles were dominated by perennial grasses and saltbush shrubs, with much less <br />cheatgrass cover. We continue to be of the opinion that reverse soil handling is likely to <br />Deserado Mine Apri130, 2002 <br />8 <br />