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22. Exhibits 3.7.2 and 3.7.4, both leases, have expired on September 1, 1990 and October 1, <br />1990, respectively. Please provide copies of renewed leases for insertion in the permit <br />application package. <br />23. Page 4.3-7 indicates topsoil is to be replaced on parts of the West Ridge mining area <br />beginning in "year 1." Please review and/or revise this timetable to accurately reflect the <br />progress of ongoing reclamation work. <br />24. Tables 4.3-4 and 4.3-5 appear to contain conflicting information. Table 4.3-4 indicates <br />144,600 cubic yards of topsoil have been stockpiled in the West Ridge area. Table 4.3-5 <br />indicates 110,000 cubic yards of topsoil will be replaced in the West Ridge area. Please <br />explain or correct the 34,600 cubic yard discrepancy. <br />2S. Table 4.3-4 indicates 102.7 acres in the West Ridge area will have topsoil redistributed <br />while Table 4.3-5 indicates 96.4 acres will have topsoil redistributed. Please explain or <br />correct this discrepancy. <br />26. Section 4.3 and Table 4.3-5 specify acreages and topsoil replacement depths for West <br />Ridge land owned by Chevron, U.S.A, and Long. Prior to distributing topsoil on these <br />areas, the permit should be revised to clearly delineate which areas will receive topsoil and <br />which will not. <br />27. Page 4.3-12 of the approved Edna Mine permit application states that application of <br />fertilizers to reclaimed lands during the first five years of the liability period will not result <br />in a restarting of the ten year liability period. This statement is contrary to the <br />requirements of Rule 4.IS.7(S). Please remove the aforementioned statement from the <br />text, or make the necessary revisions so that it complies with the rule. <br />28. In the Annual Reclamation Report for the Edna Mine, P&M includes the results of soil <br />fertility tests for areas of topsoil redistribution in the Moffat mining area. From those <br />results, it appears that soils are in need of amendments (deficiencies in available nitrogen <br />and potassium). Please review the results of those analyses and include, in the permit <br />application package, additional discussion of what amendments will be made to ensure that <br />nutrient levels in replaced soils are optimal. <br />29. The current due date for the Edna Mine Annual Erosion Inventory Report is April 30th <br />of each year. In order to comply with this deadline, mine personnel are conducting the <br />majority of the inventory in the Fall, with a cursory inspection after the Spring thaw. This <br />results in the possibility that significant features developing as a result of Spring snow melt, <br />not identified during the cursory inspection, would not be repaired for over one year. We <br />believe it is more appropriate to conduct the entire inventory immediately after the Spring <br />thaw, so that any features requiring repair will be repaired before the onset of winter. <br />Please revise page 4.3-21 to reflect an early summer due date for the inventory report, and <br />include a commitment to conducting the inventory and making necessary repairs during <br />the same field season. <br />P-dna Minc (00.001) May 18, 1994 <br />Midtcrm Rcvicw 11 Third Permit Tctm <br />