Laserfiche WebLink
The discrepancy between the two discussions for reclamation success needs to be eliminated. <br />The discussion in Section 2.05.4 is in compliance with the requirements of Rule 4.15.8; the <br />discussion on page 4.15-SR is not in compliance. Page 4.15-SR should be revised to be <br />consistent with Section 2.05.4. <br />18. EFCI will compaze the revegetation success on the reclaimed azeas to the reference azeas <br />delineated on Map 16. As discussed in Rule 4.15.7(4) of the regulations, reference areas can be <br />used in either of two methods for detemurring revegetation success, weighted average or <br />individual reference area comparison. The Division's Guidelines for Compliance with Land Use <br />and Vegetation Requirements provides a discussion of these options. The narrative on page 4.15- <br />4 and 4.15-SR, under Revegetation Success Criteria, implies that EFCI will use the individual <br />reference area comparison by comparing the grassland reference area to the revegetation at the <br />loadout and the refuse pile. It is implied that the Ponderosa pine-Pinyon-Juniper woodland <br />reference area will be used to establish standazds for the portaUfacilities area. Please clarify this in <br />Sections 2.05.4 (page 2.05.4-27, Determination of Revegetation Success), and 4.15.8 of the permit <br />application narrative. <br />19. EFCI has committed to extensive live shrub and tree planting at the mine site and the loadout. <br />Please include a narrative in the revegetation sections ofthe permit that includes the method <br />and timetable for these transplants as well as a method for ensuring their long-term success <br />Rule 5.02.4 <br />20. Because the mine is currently being reclaimed and the facilities are being demolished and the <br />entire azea is being backfilled and regraded, the Operator needs to relocate all required records to a <br />location that is accessible to the public (such as the county courthouse). <br />Miscellaneous <br />21. Please update Exhibit 19 -Mine Area Ponds tab, to reflect the elimination of pond 1 from the <br />mine site. <br />22. Since the loadout has been reclaimed and reseeded and has entered the period of extended <br />liability, with reseeding being done in the spring of 1999, please resolve stipulation 4 (text to <br />follow). <br />St~ulation 4 <br />WITH RESPECT TO THAT PORTION OF THE COAL LOAD-OUT LOCATED WEST <br />OF THE COUNTY ROAD 79 IDENTIFIED AS AN ALLUVIAL VALLEY FLOOR, <br />WITHIN TWO YEARS AFTER THE COMMENCEMENT OF THE PERIOD OF <br />EXTENDED LIABILITY AS SPECIFIED IN RULE 4.15.7(5) THE OPEATOR <br />SHALL COMPARE THE SOIL CHARACTERISTICS OF THE RECLAIMED AREA <br />WITH AN ADJACENT UN DISTURBED AREA. THIS COMPARISON SHALL BE <br />SUFFICIENT TO VERIFY THAT THE INFILTRATION, PERMEABILITY, AND <br />TEXTURAL CHARACTERISTICS OF THERECLAIMED SOILS HAVE BEEN <br />REESTABLISHED SUFFICIENTLY TO RENDER AREA <br />