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• WFC Stipulation Responses 2 November 8, 1985 Stipulation No. 19: WITHIN 12 MONTHS OF PERMIT ISSUANCE THE PERMITTEE MUST PROVIDE A PLAN TO THE DIVISION FOR THE RECLAMATION OF ALL DISTURBED SURFACE LANDS WHICH WILL NOT BE RETOPSOILED DURING RECLAMATION. THIS PLAN MUST INCLUDE ANALYSES OF AN APPROPRIATE NUMBER OF SAMPLES OF THE DISTURBED MATERIAL TO DEMONSTRATE SUITABILITY OF THE MATERIAL TO A DEPTH OF 40 INCHES ON THE BASIS OF TEXTURE, pH, ELECTRICAL CONDUCTIVITY, SAR, SATURATION PERCENTAGE, PERCENT ORGANIC MATTER, SELENIUM, AND BORON. THE PLAN MUST ALSO INCLUDE APPROPRIATE MEASURES WHICH WILL BE EMPLOYED DURING PREPARATION OF THE DISTURBED SURFACE PRIOR TO SEEDING (i.e., REDUCTION OF COMPACTION). IF THE ANALYSES OF THE IN-PLACE MATERIAL INDICATE THAT SUCCESSFUL REVEGETATION CANNOT BE ATTAINED, THE PERMITTEE MUST EITHER APPLY APPROPRIATE AMENDMENTS TO MAKE IT SUITABLE OR IMPORT SUITABLE MATERIAL. IF AMENDMENTS OTHER THAN NITROGEN, PHOSPHORUS, POTASSIUM, SULFUR, OR IRON ARE REQUIRED, THE PERMITTEE MUST SUBMIT THE RESULTS OF APPROPRIATE TESTS TO PROVE THE AMENDMENT MATERIAL IS SUITABLE FOR REVEGETATION. THIS PLAN WILL BE SUBMITTED AS A REVISION TO THE PERMIT. • WFC's plan for reclamation includes: 1) Ripping areas with no refuse and directly seeding, and; 2) Covering refuse with 6" of topsoil before seeding. Topsoil will be borrowed from other areas of the mine and from pond embankments. The first question is "How can you borrow from a pond embankment when the pond needs to remain in place during the bonding period. The second potential problem with this plan is that the soil material to be used is marginal at best. I feel that this soil may need to be amended. The other side of this argument is that there is vegetation growing in this material. We need to decide if amendments need to be addressed in this plan. Also, the operator needs to sample to 40". The samples submitted were to 18". Stipulation No. 20: THE PERMITTEE SHALL SUBMIT TO THE DIVISION A TABLE OF THE ACTUAL AND PROPOSED ACREAGES OF DISTURBANCE FOR EACH VEGETATION TYPE AT THE ALLEN MINE WITHIN 30 DAYS OF PERMIT ISSUANCE. FOR THOSE VEGETATION COMMUNITIES (PONDEROSA PINE - OAK - DOUGLAS FIR, OR WILLOW CARR, WHICH COMPRISE 5 (FIVE) PERCENT OR LESS OF THE LIFE-OF-MINE AFFECTED ACREAGE, NO ADDITIONAL BASELINE SAMPLING WILL BE REQUIRED. Although not in table form, vegetation type information. • photos, indicates less total application. I have not bee disturbed acreage. the operator has submitted disturbance by The current information, taken from 1982 aerial area disturbed than the original permit n able to get hold of a planimeter to verify the