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<br />- 4 - January 10, 1989 <br />* 15. Revised table 5-2 indicates that topsoil would be salvaged from <br />130.3 acres. This conflicts with information on the renewal <br />application form which lists actual and permitted disturbed acreage <br />of 115 acres and page 109 which indicates a total proposed <br />disturbance of 105 acres. These discrepancies need to be resolved <br />and the relationship between actual (currently) disturbed acreage <br />and permitted (allowable) disturbed acreage needs to be clarified. <br />Based on an evaluation of shaded areas on htap 5-1, proposed <br />disturbed acreage appears to exceed 130 acres. <br />* 16. On Page 99 of the Renewal Application it is stated that topsoil <br />will be redistributed at a minimum depth of 6 inches over a small <br />segment of the disturbed area. This appears to conflict with <br />Table 5-2 and the Division's Findings Document which specifies a <br />12" topsoil replacement depth on cropland areas and an 18" <br />replacement depth on pit and fill areas reclaimed for rangeland and <br />wildlife habitat. This discrepancy should be resolved and the <br />application should be modified accordingly. <br />17. To date, all salvaged topsoil has gone into stockpiles since, due <br />to the open pit mining technique employed, contemporaneous <br />reclamation has not commenced. Based on the acreage disturbed to <br />date and the approved disturbed acreage for the life of the mine, <br />the acreage to be reclaimed using stockpiled topsoils as opposed to <br />live handle topsoils should be estimated and included in <br />Section 2.05.4(2)(d) of the application. <br />XI. Vegetation <br />18. Item 6 on Page 9 of the Midterm Review Document requests that the <br />"Vegetation Information" section of the Permit Application and <br />Map 4-5 be updated to include data collected by lJestern Resources <br />Development Corporation (WRDC) in 1983. <br />The WRDC report was included as "Appendix A" to the Renewal <br />Application. An updated vegetation map was included with two <br />copies of the WRDC report submitted to the Division in January, <br />1984, but the map was not properly certified or labeled (as Map <br />4-6). <br />In order to comply with the midterm request, two copies of the <br />revised vegetation map, properly certified and labeled, should be <br />submitted for inclusion in the application. In addition, the <br />Vegetation Information section text (Page 41 - 44) of the Renewal <br />Application should be updated to reflect current conditions and <br />should refer the reader to the "Appendix A" Vegetation Study. <br />19. Item 17 on Page 10 of the Midterm Review document requests that the <br />reclamation plan be revised to specify drill seeding in all areas <br />accessible to a tractor and broadcast seeding in other areas. This <br />issue was not addressed in the Renewal Application and still needs <br />to be resolved. Table 5-7 should specify whether seeding rates are <br />based on drill seeding or broadcast seeding. <br />